Based on Government Decree 81/2025 (IV. 17.) amending Government Decree 210/2014 (VIII. 27.) on VIP cash grants (hereinafter: "Decree"), significant amendments have come into effect as of 18 April 2025.
Changes related to regional investment incentives
The rules related to regional investment incentives have been modified in several aspects. These are primarily aimed at encouraging innovative investments focusing on high value-added research and development (R&D) activities, as well as cooperation with domestic suppliers. Additionally, the system of commitments has been amended significantly.
When evaluating the potential grants, the government will consider both the added value and environmental impact of the investment. For R&D projects, the government will pay special attention to the number of patents filed by the investor or their research partners during the projects.
According to the amendments, the specific minimuThe National Tax and Customs Administration (NTCA) has published its tax audit plan for 2025, in which it confirms that transfer pricing will continue to be a priority during tax audits.
The plan reveals that significant organizational changes have taken place. In line with expectations and to be able to conduct effective tax audits, four new Transfer Pricing Expert Units came into effect on March 1, 2025, to enhance the quantity and quality of transfer pricing audits.
As part of its tax audit plan, the NTCA will focus on the following key transfer pricing areas:
- Investigation of pricing practices and specific transaction types between related parties
Particular attention will be given to transactions involving intangible assets, financing structures and solutions, and pricing models applied by distributors and agents.
- Accuracy of transfer pricing documentation and related TP disclosure obligations
TP disclosure plays a crucial role in identifying high-risk transactions, so ensuring compliance with these obligations will be a priority.
- Examination of loss-making or low-profit companies
Particular focus will be placed on companies engaged in manufacturing activity that reports continuous losses or low profitability.
- Country-by-country reporting (CbCR) and cross-border structures audit
Hungarian subsidiaries that report losses while profits are accumulated elsewhere will come under special scrutiny.
Why is this important?
Proper preparation of transfer pricing documentation is crucial for successful tax audits. If a transaction or activity resulted in lower profitability, consulting a qualified expert is recommended to assess related risks and explore available options.
If you require further information or have any questions regarding the above, please do not hesitate to contact us by phone, email, or in person. Our colleagues are happy to assist you with any inquiries and help you to identify the solution that best meets your needs.
