Navigating The New Era: Understanding Hungary's Updated Transfer Pricing Rules

I. Introduction

Recently there were some changes in Hungary in the transfer pricing documentation obligations, which is applicable to the financial year of 2023. Since the 2023 corporate income tax return filing deadline is fast approaching, we hereby summarize the changes that should be considered for the 2023 financial year (however, these have been published for a year now) The changes outlined indicate that in the future, the Tax Authority will scrutinize even more closely the substantiation of the market nature of related-party transactions. Most of the changes can be regarded as tightening. Additionally, the Tax Authority will exercise greater scrutiny during audits. In our series of articles, we will present the renewed rules, the direction of the changes, the most frequently asked questions, and the experiences of audits conducted so far.