On 23 December 2025, the Hungarian Ministry for National Economy (NGM) announced the final Hungarian transfer pricing decree 2026, officially published as Decree 45/2025 (XII. 23.) NGM on transfer pricing documentation and transfer pricing data reporting. The decree enters into force on the 31st day following publication, i.e., on 23 January 2026, replacing the currently effective Decree 32/2017 (X. 18.) NGM and redefining the framework of transfer pricing obligations in Hungary.
The draft of the Hungarian transfer pricing decree 2026 was published on 2 December 2025. We previously provided a detailed analysis of the draft’s key elements and the expected impacts. Below, we summarise the main changes compared to the current rules and highlight where the final text differs from the previously announced draft provisions.
Key changes in transfer pricing regulation
The Hungarian transfer pricing decree 2026 introduces substantial changes beyond technical adjustments:
- More unified regulatory framework: Transfer pricing documentation and data reporting are integrated into a single system, emphasising alignment with OECD Transfer Pricing Guidelines, proportional tax administration, and supporting tax authority risk analysis.
- Revised conceptual framework: The decree eliminates the TESZOR-based approach for low value-added services and codifies new concepts previously applied in practice. For determining related-party transactions, actual economic substance prevails – meaning a transaction may be relevant for transfer pricing even without invoicing.
- Modified thresholds: A new HUF 500 million threshold applies for preparing the master file, while the exemption threshold for local files rises to HUF 150 million. At the same time, certain transactions previously automatically exempt will face stricter rules.
- Simplified local file: A reduced-content documentation format will be introduced not only for low value-added services but also for other specified transactions.
- Narrower aggregation possibilities: The Hungarian transfer pricing decree 2026 clarifies which transaction types cannot be aggregated going forward.
- More detailed documentation requirements: Stronger emphasis on functional and risk analysis, mandatory benefit test for services, more precise transaction type designations, and detailed presentation of related-party relationships.
- Segmented profit and loss statement: The decree formally requires segment-level profitability analysis for related-party transactions.
- Regulation of database searches: Minimum comparability criteria and the applicable geographic hierarchy are now defined at the legislative level.
- Standardised language rules: The decree specifies the languages permitted for preparing documentation, amendments, and supporting materials.
How does the final Hungarian transfer pricing decree 2026 differ from the draft?
While the final decree follows the structure and logic of the draft, it includes significant clarifications and modifications.
Narrower master file obligation
The draft considered the total value of all related-party transactions when applying the HUF 500 million threshold for master file preparation. The final decree only considers transactions requiring a local file, potentially reducing the number of taxpayers subject to master file requirements.
Broader language options
The final text allows transfer pricing documentation, amendments, and supporting materials to be prepared not only in Hungarian and English but also in German – an important practical relief for international groups with German connections.
Consignment sales – planned simplification not implemented
Beyond limited-risk distribution, the draft legislation would have allowed the application of the transactional net margin method and net margin, as well as the designation of the distributor as the tested party in the context of consignment-based distribution, without requiring separate justification. The final decree does not include this easing, therefore detailed explanations remain necessary for the transactions concerned.
Clarifications on database searches
The draft specified conditions for conducting database searches, whereas the final decree defined the requirements for the final sample. This means compliance must extend beyond search strategy to the final set of comparable companies.
Entry into force and application
The new Hungarian transfer pricing decree 2026 applies mandatorily to tax years starting in 2026. This remains unchanged from the draft. However, the option for early application has been narrowed: while the draft allowed taxpayers to apply the new rules to documentation for corporate tax obligations starting in 2025, the final text limits this to certain local files only – excluding master file provisions.
How should taxpayers prepare?
Given these changes, we recommend that companies review their related-party transactions during the preparation phase of transfer pricing documentation for 2025 to assess where the new decree could apply. Preparation should include revisiting existing transfer pricing policies, functional analyses, and data collection processes to ensure compliance with the documentation and reporting requirements introduced by the Hungarian transfer pricing decree 2026.
The transfer pricing consulting team of WTS Klient Hungary has extensive experience in interpreting transfer pricing regulations and preparing documentation. We are ready to assist clients in assessing how the Hungarian transfer pricing decree 2026 will affect their company. As a member of the WTS Global transfer pricing consulting team, we also offer solutions for all transfer pricing-related issues at an international level. Feel free to contact our experts!
This article provides general information and does not constitute advice.
