On December 23, 2025, Hungary enacted Decree No. 45/2025, setting new transfer‑pricing documentation thresholds. The decree requires local files for related‑party transactions above 150 million HUF and master files for those above 500 million HUF, while offering simplified documentation for low‑value services.
Transactions at usual market price exceeding 150 million Hungarian forints (US$452,196) in the tax year require a local file.
When the total net value of a related‑party transaction priced at arm’s length exceeds 500 million Hungarian forints (US$1.5 million).
Yes, for taxpayers providing low‑value added services, subject to conditions.
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Bloomberg Tax · 2 days ago
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SII Spain · about 5 hours ago
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Bloomberg Tax · about 8 hours ago
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