On 18 October 2022, Hungarian Ministry of Finance has submitted a draft legislation to the Parliament proposing the amendments of advance pricing arrangements (APAs) and introduction of public CbC reporting.
Effective from 1 January 2023, the amended APA rules will be applicable providing that APA applications can only be made for full tax years, and duration of the duration of the bilateral and multilateral processes would be slightly limited. When the changes come into effect, the fees for APA extensions would be increased and the regulations on the ban on tax audits in APA procedures would be specified.
In line with EU rules, the draft legislation would require multinational groups to disclose certain tax-related information on a CbC basis for financial years beginning on or after 22 June 2024.
