- Updated
- October 2025
- Sections
- 13
- Questions
- 37
Key Facts
Core Framework
Section 18 of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax
Section 31 (2) (b) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax
The OECD TP Guidelines are not legally binding in Hungary; however, the Hungarian TP regulations are based on the OECD Transfer Pricing Guidelines. Section 3 1(2) (b) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax contains reference to the OECD TPG.
Section 31(2) (b) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax.
Hungarian regulations follow the guidance in Chapter III of the TPG.
Local companies are preferred in comparability analyses. The geographic selection criteria is as follows: Hungary, Visegrád countries (HU, SK, CZ, PL) and if necessary, the scope can be extended further.
Section 18 (9) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax.
Non-official English translation of Section 18 (9) of Act LXXXI of 1996 on Corporate Tax and Dividend Tax is the following: (9) If considered justified in the application of the methods provided for in Subsection (2) (having regard in particular to functionality analysis, sample composition or extreme values), the taxpayer shall apply additional filters relying on the median range covering half of the sample components (interquartile range), taking into consideration the ministerial decree laying down provisions for the obligation to keep records relating to the determination of fair market value adopted under authorization by this Act.
Documentation
Section 18 (5) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax. Decree No 32/2017. (X.18) of the Ministry for National Economy on transfer pricing documentation requirements. Section V/D. of the Act XXXVII of 2013 on the rules of international administrative co operation related to taxes and other duties. Act XCI of 2017 on the multilateral exchange of information of CbCR between competent authorities.
Section 18 (5) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax. Decree No 32/2017. (X.18) of the Ministry for National Economy on transfer pricing documentation requirements. Section V/D. of the Act XXXVII of 2013 on the rules of international administrative co operation related to taxes and other duties. Act XCI of 2017 on the multilateral exchange of information of CbCR between competent authorities.
Section 18 (5) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax. Decree No 32/2017. (X.18) of the Ministry for National Economy on transfer pricing documentation requirements. Section V/D. of the Act XXXVII of 2013 on the rules of international administrative co operation related to taxes and other duties. Act XCI of 2017 on the multilateral exchange of information of CbCR between competent authorities.
Section 230 of the Act CL of 2017 on the Rules of Taxation. Section 43/S. of the Act XXXVII of 2013 on the rules of international administrative co operation related to taxes and other duties.
Master File and Local File: Default penalty may be imposed up to HUF 5 million with regard to incomplete or inaccurate information, non-filing or late filing of the Master file and/or Local file. In case of a repeated infringement the taxpayer may be subject to a default penalty four times the amount imposed in the first instance. If the documentation obligation is fulfilled prior to bringing the decision due to the repeated failure, the default penalty may be reduced or waived. CbCR: If the CbC Report is incomplete or contains inaccurate information, or it is submitted after deadline, a default penalty up to HUF 20 million may be imposed.
TP Methods
- CUP
- Resale Price
- Cost Plus
- TNMM
- Profit Split
- Other
Selection: Most appropriate method
Dispute Resolution
Sections 174 – 183 of the Act CL of 2017 on the Rules of Taxation; Sections 111 – 116 of the Government Decree No. 465/2017. on the Detailed Rules of Tax Administration Procedures; Act XXXVI of 2006 on the Promulgation of the Arbitration Convention; Section 42 of the Act XXXVII of 2013 on the rules of international administrative co operation related to taxes and other duties
For the APAs and MAP, please see the link on the left.
Sections 174 – 183 of the Act CL of 2017 on the Rules of Taxation; Sections 111 – 116 of the Government Decree No. 465/2017. on the Detailed Rules of Tax Administration Procedures; Act XXXVI of 2006 on the Promulgation of the Arbitration Convention; Section 42 of the Act XXXVII of 2013 on the rules of international administrative co operation related to taxes and other duties
For the APAs and MAP, please see the link on the left.
Simplifications
The application of the Simplified and Streamlined Approach is still under consideration in Hungary.
Special Topics
Section 31(2) (b) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax.
The TPG is followed in general.
Section 31 (2) (b) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax.
The TPG is followed in general.
The TPG is followed in general.
Section 31(2) (b) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax.
The TPG is generally followed.
Full OECD Questionnaire
Legal ReferenceSection 18 of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax
Legal ReferenceSection 31 (2) (b) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax
The OECD TP Guidelines are not legally binding in Hungary; however, the Hungarian TP regulations are based on the OECD Transfer Pricing Guidelines. Section 3 1(2) (b) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax contains reference to the OECD TPG.
Legal ReferenceSection 4 (23) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax
Non-official English translation of Section 4 (23) of Act LXXXI of 1996 on Corporate Tax and Dividend Tax provides the definition of related parties for transfer pricing purposes: 23. affiliated company shall mean: a) the taxpayer and the person in which the taxpayer has a majority control - whether directly or indirectly - according to the provisions of the Civil Code; b) the taxpayer and the person that has majority control in the taxpayer - whether directly or indirectly - according to the provisions of the Civil Code; c) the taxpayer and another person if a third party has majority control in both the taxpayer and such other person - whether directly or indirectly - according to the provisions of the Civil Code, where any close relative holding a majority control in the taxpayer and the other person shall be recognized as third parties; d) the foreign enterprise and its domestic permanent establishment and the permanent establishments of the foreign enterprise, furthermore, the domestic permanent establishment of the foreign enterprise and any person that is in a relationship with the foreign enterprise as defined in points a) to c); e) the taxpayer and its foreign permanent establishment, as well as the foreign permanent establishment of the taxpayer and any person that is in a relationship with the taxpayer as defined in points a) to c); f) the taxpayer and another person if due to the equivalence of management between them dominating influence is exercised over business and financial policy; g) in addition to the provisions of points a) to c) affiliation shall be considered to exist ga) for the purposes of Point 11, Point 53, Section 8 (1) f), and Section 16/A, if there is at least 25% direct or indirect voting right, or at least 25% direct or indirect equity participation, or at least 25% profit entitlement between the taxpayer and another person, or if a third person holds at least 25% direct or indirect voting right, equity participation, or profit entitlement in both the taxpayer and the other person, provided that compliance with point f) does not need to be examined in the application of this provision; gb) for the purposes of Section 2 (7) and Section 16/B, if there is at least 50% direct or indirect voting right, equity participation, or profit entitlement between the taxpayer and another person, where the influence of persons acting in concert must be aggregated for the purposes of voting rights and equity participation, and in the case of taxpayers belonging to a group preparing consolidated financial statements, compliance with point f) must also be examined.
Legal ReferenceSection 18 (2) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax
Other methods should be used if the arm’s length price cannot be determined by none of CUP, resale price, cost plus, TNMM, or profit split method.
- CUP (provided)
- Resale Price (provided)
- Cost Plus (provided)
- TNMM (provided)
- Profit Split (provided)
- Other (provided)
Legal ReferenceSection 31 (2) (b) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax
The most appropriate method should be interpreted as in the TPG.
- Hierarchy of methods (not selected)
- Most appropriate method (selected)
Legal ReferenceSection 31 (2) (b) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax
For controlled transactions involving commodities, the guidance contained in paragraphs 2.18-2.22 of the TPG is followed.
Legal ReferenceSection 31(2) (b) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax.
Hungarian regulations follow the guidance in Chapter III of the TPG.
Local companies are preferred in comparability analyses. The geographic selection criteria is as follows: Hungary, Visegrád countries (HU, SK, CZ, PL) and if necessary, the scope can be extended further.
Legal ReferenceSection 18 (9) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax.
Non-official English translation of Section 18 (9) of Act LXXXI of 1996 on Corporate Tax and Dividend Tax is the following: (9) If considered justified in the application of the methods provided for in Subsection (2) (having regard in particular to functionality analysis, sample composition or extreme values), the taxpayer shall apply additional filters relying on the median range covering half of the sample components (interquartile range), taking into consideration the ministerial decree laying down provisions for the obligation to keep records relating to the determination of fair market value adopted under authorization by this Act.
Legal ReferenceSection 7 of the Decree No 32/2017. (X.18) of the Ministry for National Economy on transfer pricing documentation requirements.
There is the possibility to use comparability adjustments, but it is not mandatory as asked in this question. The taxpayer may apply adjustments that are contained (or not) in the TPG in order to improve comparability. Adjustments should be properly documented and justified.
Legal ReferenceSection 31(2) (b) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax.
The TPG is followed in general.
Legal ReferenceSection 31(2) (b) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax.
The TPG is followed in general.
Legal ReferenceSection 31 (2) (b) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax.
The TPG is followed in general.
The TPG is followed in general.
Legal ReferenceSection 5 of the Decree No 32/2017. (X.18) of the Ministry for National Economy on transfer pricing documentation requirements.
Legislation is based on OECD TPG and the guidelines on low value-adding intra-group services of the EU Transfer Pricing Forum with certain additional restrictions.
There are a number of direct, indirect, and municipal tax legislation that include rules for the tax treatment of controlled or uncontrolled transactions involving services. These are not transfer pricing rules therefore these do not fall within the scope of the transfer pricing country profile.
Legal ReferenceSection 31(2) (b) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax.
The TPG is generally followed.
Legal ReferenceSection 8 (1) (j) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax.
Interest deduction limitation in corporate income tax is harmonised to EU directives 1164/2016 and 952/2017, which are issued by the EU on the basis of BEPS 4.
Legal ReferenceSection 31 (2) (b) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax.
The TPG is generally followed.
Legal ReferenceSection 18 (5) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax. Decree No 32/2017. (X.18) of the Ministry for National Economy on transfer pricing documentation requirements. Section V/D. of the Act XXXVII of 2013 on the rules of international administrative co operation related to taxes and other duties. Act XCI of 2017 on the multilateral exchange of information of CbCR between competent authorities.
- Master file consistent with Annex I to Chapter V of the TPG (selected)
- Local file consistent with Annex II to Chapter V of the TPG (selected)
- Country-by-country report consistent with Annex III to Chapter V of the TPG (selected)
- Specific transfer pricing returns (separate or annexed to the tax return) (selected)
Legal ReferenceDecree No 32/2017. (X.18) of the Ministry for National Economy on transfer pricing documentation requirements. Annex 3 of the Act XXXVII of 2013 on the rules of international administrative cooperation related to taxes and other duties.
The preparation deadline of the transfer pricing documentation and the transfer pricing data reporting obligation is the filing deadline of the corporate income tax return, which is the last day of the fifth month following the end of the respective tax year. However, if the Master file is not available due to the legislation applicable to the ultimate parent company of the group, then the deadline for preparing the Master file is no later than 12 months after last day of the taxpayer's tax year. The language of the transfer pricing documentation is any language chosen by the taxpayer. Upon request, the taxpayer shall be obliged to hand over the Hungarian translation of the transfer pricing documentation. All domestic entities of MNEs under the scope of CbC Reporting are required to file a notification before the end of the reporting fiscal year, in which they indicate their filing status. Both the notification and the CbC Report need to be filed electronically, using the Hungarian domestic form. CbCR shall be submitted within 12 months after the last day of the financial year reported.
Legal ReferenceSection 230 of the Act CL of 2017 on the Rules of Taxation. Section 43/S. of the Act XXXVII of 2013 on the rules of international administrative co operation related to taxes and other duties.
Master File and Local File: Default penalty may be imposed up to HUF 5 million with regard to incomplete or inaccurate information, non-filing or late filing of the Master file and/or Local file. In case of a repeated infringement the taxpayer may be subject to a default penalty four times the amount imposed in the first instance. If the documentation obligation is fulfilled prior to bringing the decision due to the repeated failure, the default penalty may be reduced or waived. CbCR: If the CbC Report is incomplete or contains inaccurate information, or it is submitted after deadline, a default penalty up to HUF 20 million may be imposed.
Legal ReferenceSection 18 (3) and (5) of the Act LXXXI of 1996 on Corporate Tax and Dividend Tax.
Local file and Master file: The following transactions are number of exempt from the transfer pricing documentation obligation: a) a contract concluded with a private individual who is not an individual entrepreneur, b) the related party transaction covered by an Advance Pricing Agreement, c) cost recharge transactions in an unchanged amount or value, provided that the person providing the service or selling the goods is not a related entity with the taxpayer, foreign person, or the party bearing the cost, d) the transfer and receipt of monetary funds free of charge, e) if the value of the transaction does not exceed HUF 100 million at the fair market price excluding VAT, provided that when determining the value threshold the rules of aggregation must be taken into account, i.e. the value of the aggregable transaction should be determined jointly f) the stock exchange transaction according to the Act on the Capital Market, g) the transaction realized by applying a price fixed by the authorities or a specific price individually determined in a legislation. CbCR: Multinational enterprises are not required to prepare CbCR if their consolidated revenue is under EUR 750 million in the financial year preceding the financial year reported.
Legal ReferenceSections 174 – 183 of the Act CL of 2017 on the Rules of Taxation; Sections 111 – 116 of the Government Decree No. 465/2017. on the Detailed Rules of Tax Administration Procedures; Act XXXVI of 2006 on the Promulgation of the Arbitration Convention; Section 42 of the Act XXXVII of 2013 on the rules of international administrative co operation related to taxes and other duties
For the APAs and MAP, please see the link on the left.
- Rulings (selected)
- Enhanced engagement or cooperative compliance programmes (not selected)
- Advance Pricing Agreements (APA) (selected)
- Mutual Agreement Procedures (selected)
- International Compliance Assurance Programme (ICAP) (not selected)
The application of the Simplified and Streamlined Approach is still under consideration in Hungary.
- N/A (selected)
- N/A (selected)
Legal ReferenceSection 18 (1) of Act LXXXI of 1996 on Corporate Tax and Dividend Tax
Non-official English translation of Section 18 (1) of Act LXXXI of 1996 on Corporate Tax and Dividend Tax is the following: If related parties apply a consideration (excluding value added tax) in their contracts or agreements that is higher or lower than the arm’s length price, the taxpayer shall adjust its pre-tax profit by the amount of the difference between the arm’s length price and the applied consideration—irrespective of any other pre-tax profit increasing or decreasing items prescribed by this Act — a) decreases the pre-tax profit, provided that: aa) as a result of the applied consideration, the taxpayer's pre-tax profit is higher than it would have been if the arm’s length price had been applied; ab) the related party to the transaction is a resident taxpayer in Hungary or a foreign entity (excluding a controlled foreign company) that is subject to a corporate income tax or a similar tax under the laws of its country of residence; ac) the taxpayer possesses a document, signed by both parties, stating the amount of the difference; and ad) the taxpayer possesses a declaration from the other party stating that the difference (the amount determined based on the arm’s length principle applicable to the other party) has been or will be taken into account in determining its tax base for corporate income tax or an equivalent tax.
Yes. Year-end adjustments are allowed.
In the vast majority of the double tax treaties of Hungary concluded after 2010 the new version of Article 7 is included. Some of our treaties concluded after 2010 and our older treaties however contain the previous (“old”) version of Article 7. Hungary as a member of the OECD follows the latest standards as a general rule in relation to treaty interpretation. The Corporate Income Tax Act lays down as a basic principle that international agreements promulgated (double tax treaties) shall override the provisions of the Act.
- Article 7 as it read before 2010. (not selected)
- Article 7 as it reads after 2010. (selected)
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