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Hungary: Guidance on new transfer pricing documentation and reporting rules

Applicable to tax years beginning in 2026

august 26, 2026

The Ministry of Finance published guidance on the application of the new transfer pricing documentation and reporting rules under Decree 45/2025, which apply to tax years beginning in 2026.

The guidance highlights key compliance areas, including financial data segmentation, benefit test documentation, related-party ownership disclosures, treatment of non-invoiced and free-of-charge transactions, benchmarking requirements, DEMPE analysis for intangibles, and revised rules for low value-adding services.
 

For more information, contact a KPMG tax professional in Hungary:

Mihály Gódor | mihaly.godor@kpmg.hu

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