What does the new draft transfer pricing decree mean?

Will administrative burdens genuinely decrease, or is the framework tightening?

In the first week of December 2025, the Ministry of National Economy published a draft of a new regulation on transfer pricing documentation and transfer pricing data reporting. The proposal would comprehensively amend the current documentation rules, setting new requirements in several areas, while also introducing certain simplifications. The aim of the new regulation is to reduce the administrative burden and improve the performance of tax audits by making it easier to detect errors.

The new regulation will be mandatory for the first time for the 2026 tax year, but taxpayers may choose to apply it already for the 2025 business year. However, this choice should be assessed on a case-by-case basis, as there are significant influencing factors on both sides of the equation.

Below we summarize the most important changes affecting taxpayers' obligations.

Changes in the value thresholds for preparing transfer pricing documentation and data reporting obligations

Master file
A new feature is that, unlike in the past, a Master file is only required if the net aggregated value of the taxpayer's transactions with related parties in a given tax year exceeds HUF 500 million.

Local file and data reporting
Unlike before, the threshold for the preparation of transfer pricing documentation at taxpayer and transaction level and for the fulfillment of data reporting obligations within the corporate tax return will increase from HUF 100 million to HUF 150 million.

When determining the thresholds, the rules on the consolidated treatment of transactions - which have undergone further amendments - must continue to be taken into account.

Cases of exemption from transfer pricing obligations

The cases of exemption from the obligation to prepare transfer pricing documentation and fulfilling data reporting obligations will change as follows under the new regulation:

• Transactions involving the transfer or receipt of funds free of charge are subject to transfer pricing documentation requirements under the new regulation.
• Cost recharges are not subject to transfer pricing documentation requirements only if the total value of such transactions in a given tax year does not exceed HUF 500 million.
• Furthermore, as a rule, only transactions below HUF 150 million are exempt from the data reporting obligation. For stock exchange transactions and transactions at official prices or prices specified by law, taxpayers are only exempt from the data reporting obligation if the net value of the transaction does not exceed HUF 500 million in the tax year.
• A Simplified Local file will be introduced, which can be prepared not only for low value-added services, but also for free transfer of funds and cost recharge transactions.

Rules on retention and language of transfer pricing documentation

The draft stipulates that taxpayers must retain the Local file and its appendices in a readable form for at least eight years. In case of related-party transactions involving fixed assets, the retention period is at least eight years from the date of final derecognition of the asset.

Another change is that, unlike previously, transfer pricing documentation may be prepared only in Hungarian or English.

Changes to the mandatory content of transfer pricing documentation

The new regulation also introduces changes to the mandatory content requirements. Without being exhaustive, the changes affect the following rules:

• Among other things, in order to link data reporting and transfer pricing documentation, transaction-level documents must include the transaction name indicated in the data report and the most relevant TEÁOR (NACE) code.
• Taxpayers must present data on their related parties in much greater detail than before.
• In addition, the new regulation sets further requirements concerning the detail of economic analyses and the related data to be reported (e.g., regarding their link to the accounting information system) and on the supporting documentation for the pricing of individual related-party transactions.
• Stricter segmentation and financial requirements: based on the draft, not only the taxpayer but also its related parties (even foreign ones) will have to provide much more detailed financial information for the preparation of the Local file.
• The new regulation contains further tightening for certain parts of the Local file (e.g., more detailed functional analysis, mandatory benefit test).

Revision of the concept of low value-added services

The new regulation redefines the concept of low value-added services: rather than regulating and narrowing the scope based on specified TESZOR codes, but it will require analysis and justification of the economic circumstances of the transaction, the functions performed and risks assumed.

Transfer pricing documentation for such transactions may continue to be prepared in a simplified form if the taxpayer, as the provider of low value-added services, achieves effectively a net profit margin of at least 5%, or if the related party/parties achieve a net profit margin of no more than 5% in providing the services used by the taxpayer. In line with the above, the taxpayer will only have a limited transfer pricing reporting obligation for these kinds of transactions.
 

Amendment of the rules on aggregation

The new regulation maintains the main principles of the current rules on the aggregation of related-party transactions. The new regulation determines the non-aggregation of incoming and outgoing transactions based on the taxpayer’s role in the transaction (supplier or buyer).

The possibility of aggregation will be excluded between five broad categories of transactions (manufacturing, distribution, service, financial transactions, and transactions involving intangible assets).

Amendment to the regulations governing the preparation of comparative studies

Under the new regulation, taxpayers must base their comparability analyses on data available no later than at the time of fulfilling the transfer pricing documentation obligation, rather than at the time of the transaction.

Although the Tax Authority has previously objected to the centrally prepared so-called pan-European benchmarks, the new regulations require the preparation of territorial or regional benchmark analyses aligned with the region of the tested party.

Changes to transfer pricing reporting requirements

The new decree broadens the labels of certain types of transactions and splits transactions that cannot be classified into other categories according to the incoming and outgoing sides (supplier or customer side).
The new regulation confirms that the amounts to be included in the data report must be stated in thousand Hungarian forints. In addition, it modifies the names of the selectable profitability indicators and defines them in the definitions section.

Furthermore, the new decree requires that the taxpayer, as the tested party, determine the profitability indicator and other financial figures necessary for the calculation based on the accounting standard used to prepare its officially published individual financial statements. In addition, the new regulation also clarifies the requirements for certain parts of the data reporting.

In summary
Although the new regulation increases the documentation thresholds and exempts the preparation of the Master file in certain cases, on the other hand, it makes documentation mandatory for several types of transactions that were previously exempt. In addition, it provides important clarifications regarding the preparation of transfer pricing documentation and economic analyses. However, in most cases, these clarifications mean that more detailed mandatory content elements must be included in the transfer pricing documentation. Overall, it can be said that transfer pricing documentation regulations have become stricter in Hungary.