On 27 July 2022, the Hungarian Official Gazette published the Budget Bill (Law XXIV of 2022) providing for amendments to the Hungarian transfer pricing regulations. The law was passed by the parliament on 19 July 2022. The law includes the following tax measures related to transfer pricing obligation.
- For TP documentation, taxpayers are required to provide transaction-level details of their controlled transactions in their annual corporate income tax returns.
- The use of the interquartile range will always be mandatory for comparable searches based on a public database.
- The penalty for violating TP documentation requirements will be increased from HUF 2 million to HUF 5 million per intra-group transaction.
The obligation to submit transfer pricing information with the CIT return applies for the first time in a return filed after 31 December 2022.
