BDO Transfer Pricing Questionnaire

New transfer pricing regulation 2026 – which regulation should you choose for 2025?

Why is it worth completing this questionnaire?

On January 1, 2026, a new transfer pricing regulation will come into force in Hungary, significantly changing the rules for documenting related-party transactions.

However, the legislation allows taxpayers to choose whether to prepare their records for the 2025 fiscal year based on the old or new transfer pricing regulations.

The decision is not a technical detail, but has a direct impact on:

• the scope and cost of documentation,
• administrative burdens,
• and the risk of NAV audits.

This questionnaire helps businesses make quick and informed decisions.

Transfer pricing documentation is one of the key areas of focus for NAV audits.

In the event of incomplete or inadequate documentation, significant penalties may be imposed, regardless of whether the prices applied can be considered market prices.

Since 2025 is a transitional year, choosing the wrong regulations may:

• cause unnecessary extra work, or
• result in unjustified risk.

The decision between the old and new transfer pricing regulations has different consequences in several aspects:

• The new regulation imposes stricter and more detailed content requirements on the local document (DEMPE analysis, more complex company-level analysis).
• Under the new regulations, no local documentation is required for transactions with an annual value of under HUF 150 million (compared to the previous threshold of HUF 100 million).
• Under the new rules, a master file is not mandatory for transactions with a value of under HUF 500 million.
• New exemptions and simplifications have been introduced, including the option of a simplified local file.
• The year 2025 will give businesses the opportunity to test the mandatory transition to 2026 without risk.

Important information

It is important to note that the results of the questionnaire do not constitute tax or transfer pricing advice.

In order to comply with the transfer pricing obligations for 2025, it is necessary to engage a tax advisor and transfer pricing expert.

Fill out the questionnaire and determine which regulations you should use as a basis for preparing your transfer pricing documentation!