Recognised across four key tax disciplines 

International Tax Review’s annual awards programme is widely regarded as one of the most prestigious distinctions in the global tax advisory profession. For more than two decades, the awards have recognised leading firms, expert teams and outstanding professionals across a broad range of tax specialisations. In addition to evaluating the complexity and impact of client engagements, the judging panel considers innovation, advances in tax technology, achievements in compliance and reporting, and initiatives promoting diversity, equity and inclusion. 

For 2026, WTS Klient Hungary has been shortlisted in the following categories: 

• Hungary Indirect Tax Advisory Firm of the Year
• Hungary Tax Disputes Advisory Firm of the Year
• Hungary Transfer Pricing Advisory Firm of the Year
• Hungary Tax Advisory Firm of the Year

Strong international recognition for WTS Global 

The WTS Global network, represented in more than 100 countries, also achieved outstanding results in this year’s awards programme.

WTS Global was shortlisted in the following international categories: 

• Tax Compliance & Reporting Advisory Firm of the Year
• Tax Technology Firm of the Year
• Transfer Pricing Technology Firm of the Year
• Indirect Tax Advisory Firm of the Year
• Transfer Pricing Advisory Firm of the Year
• Tax Advisory Firm of the Year

These nominations underline the network’s extensive expertise and its strong international reputation across tax advisory, tax technology, transfer pricing and tax compliance services. 

Individual excellence recognised 

The 2026 shortlist also highlights the achievements of WTS professionals. Nils Bleckmann, indirect tax expert at WTS Germany, was shortlisted for Indirect Tax Practice Leader of the Year, while Artem Scherbyna of KM Partners was nominated in the Tax Advisory Rising Star category. 

The winners of the ITR Europe Tax Awards 2026 will be announced on Thursday 17 September 2026 at the Awards Ceremony at The Londoner, Leicester Square, London.

A ITR Europe Tax Awards 2026: WTS Klient Hungary shortlisted in four categories  bejegyzés először WTS Klient Hungary | tax | accounting | payroll | advisory | HR services | digital solutions | state aid-én jelent meg.

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.

A Hungarian transfer pricing decree 2026 published bejegyzés először WTS Klient Hungary | tax | accounting | payroll | advisory | HR services | digital solutions | state aid-én jelent meg.