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This article focuses on the upcoming transfer pricing changes in Hungary.
The new transfer pricing decree and new transfer pricing rules in Hungary from 2026 will fundamentally reshape the documentation and control practices of transactions between related parties.
During the year-end legislative rush, almost as a Christmas present, the Ministry for National Economy issued its latest transfer pricing decree. The 45/2025 (XII. 23.) NGM decree, promulgated on 23 December 2024, does not merely fine-tune the previous rules but fundamentally redraws the map of documentation obligations.
Although the mandatory application date is 2026, the legislator has offered taxpayers a special option: the new rules may already be applied to the 2025 financial year. But is it worth switching to the new transfer pricing rules in Hungary already in 2025, or is it safer to wait until 2026? In our analysis, we go through the most important changes, from relaxations to stricter requirements.
Transfer pricing has been one of the key targets of tax authority audits for years. The regulation now being replaced, the 2017 decree (32/2017 (X. 18.) NGM decree), served as the framework for a long time; however, the evolution of international (OECD) guidelines and domestic audit experience made renewal necessary.
The changes in transfer pricing documentation work in two directions at once: on the one hand, they aim to reduce the administrative burden for less significant transactions, while on the other hand, they place riskier transactions “under the magnifying glass”, requiring much deeper data provision and substantiation.
The most spectacular and most taxpayer-friendly element of the new transfer pricing rule is the increase of value thresholds. The exemption threshold from documentation obligations rises from the previous HUF 50 million and later HUF 100 million to HUF 150 million.
In practice, this means that if the value of a related-party transaction (or a group of transactions to be aggregated) at arm’s length does not reach HUF 150 million in the tax year, there is no need to prepare a detailed Local File.
This change may result in administrative cost savings for many small and medium-sized enterprises, as well as for large companies conducting lower-volume transactions. It is important to note, however, that exemption from documentation obligations does not mean exemption from the arm’s-length principle – pricing must still be substantiated in the event of an audit, but the burden of formal documentation is lifted.
A significant easing also affects the obligation to prepare the Master File. Under the previous regulation, if a taxpayer had to prepare a Local File for even a single transaction, it was automatically required to obtain or prepare the Master File presenting the entire group. In many cases, this imposed a disproportionate burden on smaller Hungarian subsidiaries.
From 2026, a Hungarian taxpayer does not need to prepare a Master File if the total value of transactions with related parties does not exceed HUF 500 million.
This calculation must also include transactions exempt from documentation obligations (e.g. transactions below HUF 150 million). This change particularly benefits companies that, although members of an international group, do not reach a transaction volume that would justify complex group-level presentation.
Alongside the relaxations, the new transfer pricing rules in 2026 introduce stricter professional expectations in several areas. A reduction in administration does not go hand in hand with a loosening of audit strictness – on the contrary, the focus shifts to substance and economic rationale.
In the case of service provisions – with particular emphasis on
it will no longer be sufficient merely to justify that the fee is at market level. The new transfer pricing decree explicitly prescribes the performance and documentation of the Benefit Test.
What does this mean in practice? The taxpayer must substantiate with concrete evidence that the service used:
In the absence of this, the recognition of the cost carries serious tax risk. This is especially true for “standardised” group costs (HQ services), which require more conscious contractual and performance-certification support.
The new transfer pricing rules in Hungary in 2026 also tighten requirements for profitability analyses.
If a company applies the TNMM method, financial data must be presented in a segmented manner. The decree clarifies that where a taxpayer applies a profitability-based method, it is obliged to break down its financial data by activity (by segment).
This requirement may pose a serious challenge to accounting systems.
In practice, this means that general ledger data must be structured so that the profitability of the examined related-party transaction –
can be clearly and numerically derived from the financial statements.
Using an “aggregated” income statement for the entire company for benchmarking purposes will no longer be acceptable in the future if the company performs other activities as well.
The new transfer pricing decree also clarifies the accounting of low value-added services.
In line with OECD guidelines, the simplified rules for low value-added services are also transformed. Instead of the previous banded or more flexible margin interpretation, the decree “sets in concrete” the expected level.
Simplified documentation (acceptance without benchmark) can only be chosen if the applied markup is:
If the markup differs from this (for example 3% or 7%), the taxpayer falls outside the protective umbrella of the simplified regime and must prepare a full benchmarking analysis to substantiate pricing.
The entry into force of the 45/2025 NGM decree creates an interesting transitional period. The new transfer pricing rules are mandatory from 2026 and apply for the first time to tax years starting in 2026. At the same time, the legislator allows taxpayers to choose, at their own discretion, to apply the provisions of the new decree already to the tax year starting in 2025.
This choice is not merely an administrative issue, but a serious tax-strategy decision.
Primarily those businesses where the value of transactions falls into the “critical zone”, i.e. between HUF 100 million and HUF 150 million. For them, choosing the new decree may mean immediate exemption from preparing a Local File for 2025.
Switching may also be advantageous for subsidiaries that remain below the HUF 500 million group-level turnover threshold, as they may be exempted from the Master File obligation.
Companies for which documentation obligations will in any case apply (transactions above HUF 150 million) should proceed with caution. Choosing the new decree brings not only relaxations but also stricter requirements (benefit test, strict segmentation).
If a company’s record-keeping, data-provision systems or contractual framework are not yet ready in 2025 for detailed segmented reporting or the documentation of benefit tests, it may be safer to close the 2025 year under the old 32/2017 (X. 18.) NGM decree and dedicate 2026 to preparation.
The new transfer pricing rules in 2026 represent not only a legal change but also a shift in operational mindset:
Documentation of the 2025 financial year is therefore also about preparation and evaluation: every taxpayer should have their transactions reviewed by an expert in order to decide whether applying the new or the old regulatory framework better serves their interests at year-end.
The new transfer pricing rules are mandatory from 2026 for tax years starting in 2026. At the same time, companies may decide to apply the new rules already for the 2025 tax year.
If the new rules bring administrative relief (e.g. exemption from preparing a Local File), then yes.
However, if the stricter requirements (benefit test, segmented data) cannot yet be met, it may be worth waiting until 2026.
If the value of a related-party transaction or a group of transactions to be aggregated does not reach HUF 150 million, then under the new transfer pricing rules it is not mandatory to prepare a detailed Local File.
From 2026, the obligation to prepare a Master File depends on whether the total value of transactions with related parties exceeds HUF 500 million. Below this threshold, it is not mandatory to prepare a Master File.
The benefit test examines whether a service obtained from a related party:
If these cannot be substantiated, the recognition of the cost may entail a serious tax assessment risk.
Management fees, consultancy fees and group-level services (HQ services) are most in focus, as the tax authority frequently examines their actual benefit.
It means that the company must be able to present separately, for the related-party transaction:
It is not sufficient to rely on financial data for the company “as a whole”.
Under the new transfer pricing decree, simplified settlement may only be applied if the markup is:
If there is any deviation, a full benchmarking analysis becomes necessary.
From 2026, transfer pricing audits are expected to become more substantive:
less emphasis will be placed on documents alone, and more on the examination of economic rationale (benefits, segmented data, markups).
The most important first step is a preliminary transfer pricing review that maps:
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