Hungary Gazettes Decree on Transfer Pricing Documentation, Reporting Requirements

The Hungarian Official Gazette Dec. 23, 2025, published Decree No. 45/2025, on the transfer pricing documentation and reporting requirements under the OECD Transfer Pricing Guidelines. The decree includes measures: 1) requiring local files for related-party transactions at the usual market price that exceed 150 million Hungarian forints (US$452,196) in the tax year, without VAT; 2) requiring a master file if the total net value of a related-party transaction priced at arm’s length exceeds 500 million forints (US$1.5 million); 3) allowing simplified local documentation for taxpayers providing low-value added services, subject to conditions; and 4) allowing taxpayers to apply the decree ...