New Regulations On The Transfer Pricing Documentation In Hungary

The new regulations considerably extend the requirements for the content of the documentation, prescribing a much wider range of information to be disclosed relating to the organization structure of the whole company group, the controlled transactions and the benchmark analysis.

In the local file, the required information must be disclosed as a controlled transaction, however, the aggregation rules and the simplification option for low value added services can be applied. In this latter respect, the profit margin range has been modified from 3-10% to 3-7%.