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Changes in the Intra-Group Transactions: New Transfer Pricing Decree

On 23 December 2025, the Ministry of National Economy published a new decree that reforms the current transfer pricing system with companies of common ownership and it shall be applicable for the 2026 tax year, with some of the legal provisions regarding certain local documents applicable for 2025.

The administrative burdens lighten in the wake of the new legislation. The threshold for the creation of the master file is not compulsory if the total value of the related-party transactions, calculated at normal market prices and excluding VAT, does not exceed HUF 500 million. For the compulsory creation of the local file’s threshold, this value has been raised from HUF 100 million to HUF 150 million.

The cost transfer threshold has also been raised and is free of TP, so long as the cost transfer of the given year, without VAT, on the regular market price together is not more than HUF 500 million. If the amount exceeds the limit, a simplified local file has to be produced. The free transfer of funds is no longer exempt from TP, with the new regulation, a simplified local file has to be prepared.