New transfer pricing regulation from 2026: what will change in documentation and data reporting?

Decree 45/2025. (XII. 23.) NGM was published on December 23, 2025, and will enter into force on January 23, 2026, replacing the previous transfer pricing documentation rules as a general rule from the tax years beginning in 2026. The decree does not change the fundamental objectives of transfer pricing documentation and transfer pricing reporting, but it clarifies the approaches typically used in practice in several areas. The amendments are particularly significant in terms of the content requirements for local documentation, simplifying certain points but setting out more detailed and stricter requirements in other areas.

Value limits are rising: the scope of documentation requirements may change, and the main document requirement may need to be reviewed

One of the most important and practically relevant amendments to the regulation is the increase in value limits. The exemption threshold for the Local File and transfer pricing reporting will increase from HUF 100 million to HUF 150 million (taking into account the rules on aggregation, based on the value calculated without the usual market price and VAT).

A new simplification with regard to the Master File is that it is not necessary to prepare a master file if the total value of the transactions covered by the Local File does not exceed HUF 500 million. However, when applying the threshold in practice, particular attention must be paid to the proper identification and consolidation of transactions, as the value limit is calculated taking into account the arm’s length principle.

Benefit test for services

A significant new feature of the regulation is that it makes it mandatory to prepare and document a benefit test for financial and non-financial services. In practice, this means that the documentation must support that the use of the service was actually justified from the perspective of the taxpayer’s business activity, that the service was used, and that its costs were reasonable under the circumstances. The benefit test may be particularly relevant in the case of central and management services, group-level support services (e.g., IT, HR, marketing, controlling), and regular service fees.

Clarification of methodological requirements for database searches

The regulation sets out a number of requirements for database searches (benchmark analyses) that were previously typically presented as guidelines. Only individually identifiable, active and independent companies may be included in the sample. As a general rule, the review period is the three years preceding the year under review, for which financial data must be available for all three years, and no more than one loss-making year is acceptable.

Activity screening is primarily based on the primary TEÁOR code, while keyword searches can only be used as a supplementary tool.

Segmentation of activity results

In the case of companies engaged in multiple activities, particularly if separate transfer price analyses are associated with each activity, the regulation may require the segmentation and presentation of operating results by activity. In practice, this may mean additional work for accounting and controlling systems, as defensible allocation keys and internal reporting data may be required to justify the segmentation.

Consolidated documentation

The regulation confirms that transactions in opposite directions cannot be treated as combined. Transactions must be separated according to whether they appear on the customer or supplier side in the records.

The regulation also expressly states that certain types of transactions cannot be consolidated with each other. Such categories excluded from consolidation include, in particular, manufacturing, distribution, service and financial transactions, as well as transactions related to intangible assets, which must be treated independently when reviewing documentation and value limits.

Further practical changes

• The documentation may be prepared in Hungarian, English, or German.
• The transfer pricing documentation may be amended until the start of the tax audit (an important “lifeline” in disputed situations).
• The primacy of actual economic content appears/gains strength: even in the absence of invoicing, a transaction relevant from a transfer pricing perspective may still arise.
• Records and supporting documents must be retained for 8 years.

In order to prepare, it is advisable to review the scope of related-party transactions, the practical application of documentation thresholds, and internal data reporting and control processes in a timely manner. Proper management of the changes is not only a matter of compliance, but also one of the most important tools for mitigating future tax risks.

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The experts at Central Audit Consulting Kft. provide support in reviewing related-party transactions, recalculating documentation requirements and thresholds, and in developing and reviewing compliance with the Local Documentation and Transfer Pricing Reporting Regulations.