Stricter transfer pricing rules were published

On 28 December 2022, an amendment to Decree No. 32/2017 (X. 18.) of the Ministry for National Economy on the Documentation Requirements Pertaining to the Determination of the Arm’s Length Price (“TP Decree”) was published in the Hungarian Official Journal. The TP Decree entered into force on 31 December 2022. The new rules are already in part applicable to the intra-group transactions of 2022.

In our previous newsletter, we summarized the new rules of the amendment to the TP Decree that were made available for public consultation in early December. The now-published amendment does not contain any changes. Our summary of the new additional rules is available via this link.

It is worth keeping in mind that based on the amendment, taxpayers subject to the TP documentation obligation are required to provide transaction-level details on their intercompany dealings already in their corporate income tax returns by 31 May 2023. It will be essential that the TP documentation is available in a timely manner to meet this new deadline.