Hungary: Proposed changes to transfer pricing documentation and data disclosure

The Ministry of National Economy published a draft decree on transfer pricing documentation and transfer pricing data disclosure, which would significantly revise the current transfer pricing documentation requirements from the 2026 financial year, introducing substantial additional expectations and certain simplifications in specific areas. The aim is to reduce administrative burdens, align with the OECD transfer pricing guidelines, and increase the efficiency of tax audits.

The changes include:

• Changes in thresholds (Master file, Local file): The Master file will only be mandatory if the total value of related-party transactions exceeds HUF 500 million. The exemption threshold for the Local file and data reporting will increase from HUF 100 million to HUF 150 million; however, the aggregation of similar transactions will be mandatory when determining the threshold.
• Demonstration of the benefits of received services: For all financial and non-financial services received, the application of the benefit test will be mandatory, and a deeper justification of business rationale will be required for central and management services. For transactions involving intangibles, it will become mandatory to provide a detailed description of the development, enhancement, maintenance, protection, and exploitation of the intangible asset in the economic analysis. The functional analysis must be performed using the five comparability criteria: [CL1] [MG2] contracts; functions performed; characteristics of products, goods, and services; examination of the relevant market; and the strategy pursued by the parties
• Low value-adding intra-group services: Based on OECD transfer pricing guidelines, the new decree redefines the concept of low value-adding intra-group services and introduces a simplified regulation. Under the new rules and subject to certain additional conditions, a minimum mark-up of 5% for provided services and a maximum mark-up of 5% for received services would allow for simplified documentation.
• Database searches and benchmarking studies: Market benchmarking analyses (database searches) will become more standardized, since the decree specifies a series of mandatory steps to be followed. The new territorial restrictions and sample size requirements would further reduce flexibility and may require the preparation of more benchmarking analyses compared to previous years, especially in the case of non-EU related parties.
• Segmentation: When presenting financial data, it will become mandatory to prepare a segmented statement of operating profit by activity. The allocation must cover all activities, meaning that there can be no unallocated items. If necessary, the segmented statement must also cover certain types of costs and revenues, and the methodology and justification for the allocation must be documented in detail.

Read a December 2025 report prepared by the KPMG member firm in Hungary