Hungary releases 2024 audit plan with targets transfer pricing

April 08, 2024

Hungary's National Tax and Customs Administration (NAV) has released its audit strategy for the 2024 calendar year, highlighting transfer pricing as its key area of focus among other sectors. The new transfer pricing reporting obligation introduced

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Hungary: Central bank lowers base interest rate

April 02, 2024

On 26 March 2024, Hungary’s National Tax and Customs Administration disclosed that the Hungarian National Bank has reduced the central bank base rate by 75 basis points from 9.00% and set it at 8.25%. The revised base interest rate went into

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US announces termination date of tax treaty with Hungary 

December 30, 2023

On 29 December 2023, the U.S. IRS declared in the ‘Announcement 2024-05’ the effective date of the termination of the 1979 tax treaty with Hungary. The Government of the United States provided a diplomatic notification, dated 8 July 2022, to

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Hungary offers tax amnesty for previously ineligible shares

December 20, 2023

Recently, Hungary implemented a tax legislation that grants one-time amnesty for any capital gains on the disposal of shares in subsidiaries that had not previously chosen to participate in Hungary's capital gains exemption regime. Hungary’s

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Hungary publishes GloBE laws in the official gazette

December 18, 2023

On 30 November 2023, Hungary published Law LXXXIII of 2023 on the amendment of individual tax laws and Law LXXXIV of 2023 on additional taxes in Gazette No. 171 of 30 November 2023. The recently enacted laws ensure a global minimum tax level and

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Hungary: Parliament passes pillar two global minimum tax law

November 28, 2023

On 21 November 2023, the Hungarian Parliament passed legislation to implement the Pillar 2 global minimum tax (GloBE) rules as per the Council Directive (EU) 2022/2523 of 14 December 2022.  On 17 October 2023, Hungary’s Ministry of Finance

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Hungary approves new CbC exchange agreement with the US

November 10, 2023

On 2 November 2023, Hungary formally approved signing a new Country-by-Country (CbC) exchange agreement with the United States. The agreement—Decree No. 1482/2023—was published in the Official Gazette. This follows the previous CbC exchange

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Hungary: MOF introduces draft legislation on BEPS 2.0 pillar two to parliament

November 08, 2023

On 31 October 2023, the Hungarian Ministry of Finance presented the draft legislation to the parliament regarding the implementation of  EU Directive 2022/2523 on the global minimum tax. As previously reported, the Ministry of Finance released

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Hungary: MoF initiates public consultation regarding a draft bill on pillar two

October 25, 2023

On 17 October 2023, Hungary’s Ministry of Finance initiated a public consultation process regarding a draft law for implementing the corporate minimum tax under Pillar 2 as per the Council Directive (EU) 2022/2523 of 14 December 2022. The

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Hungary publishes decree amending extra-profit tax provisions for several industries

July 25, 2023

On 17 July 2023, Hungary published Government Decree 317/2023 in the Official Gazette amending Government Decree 197/2022 on temporary windfall taxes on additional profits. One of the most important changes is the extension of the windfall tax to

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Hungary extends windfall taxes until the end of 2024

June 10, 2023

On 31 May 2023, Hungary released Government Decree 206/2023 in the Official Gazette amending Government Decree 197/2022 regarding temporary windfall taxes on additional profits. The decree includes extension of certain taxes until 2024 and making

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Hungary releases decree amending provisions on windfall taxes on petroleum products

May 13, 2023

On 29 March 2023, the Hungarian Official Gazette published Government Decree No. 100/2023 amending the provisions on windfall taxes on petroleum products imports from Russia. Under the decree, a windfall tax has been introduced on the profits of

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Hungary: MoF publishes decree amending TP rules on transfer pricing documentation

February 05, 2023

On 28 December 2022, the Hungarian Ministry of Finance published Decree 27/2022 (XII.28) which amends the Decree 32/2017 (X.18) on the documentation requirement related to the determination of arm’s length prices. Increase threshold

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Hungary: Government raises windfall tax on petroleum product producers

January 08, 2023

On 7 December 2022, Hungary published Decree 496/2022 increasing the tax rate for temporary windfall taxes. Accordingly, from 8 December 2022, oil companies will have to pay a special monthly tax rate of 95% (previously 40%) on the price difference

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Hungary: MoF publishes draft transfer pricing decree on TP reporting obligation

December 15, 2022

On 9 December 2022, the Hungarian Ministry of Finance issued a draft transfer pricing decree detailing a new transfer pricing reporting obligation. Accordingly, taxpayers are required to prepare a transfer pricing report on a transaction basis or on

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Hungary submits a draft legislation to Parliament on APA and CbCR

November 06, 2022

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

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Hungary gazettes the 2023 Budget bill including transfer pricing changes

August 10, 2022

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

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Hungary: Parliament adopts a bill imposing additional requirement for TPD

July 25, 2022

On 19 July 2022, the Hungarian Parliament passed a bill introducing important changes to the transfer pricing rules. The law introduces a significant additional reporting requirement for intra-group transactions and requires transfer pricing

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