From 2025, we are saying goodbye to the previous transfer pricing regulation and introducing a new one, which affected parties may choose to apply already for the previous year. However, from 2026 onwards, its application will be mandatory. While the new rules do include certain simplifications, they are much more characterized by stricter requirements.
It is well known that the larger and more complex a machine or organization is, the slower it can turn around and change direction. This is also true of a country's economic policy. But no matter how slow a change may be, after a while it becomes noticeable. At first, perhaps only the officers and helmsmen notice it, then the crew, and finally the passengers may also notice that the Hungarian economy, even if it has not turned around completely, has begun to move in a different direction than before.
Corporate transformation is a process that requires interdisciplinary cooperation. Its success depends on the joint efforts and collaborative thinking of tax, legal, and accounting professionals.
On November 19, 2025, the OECD clarified the rules on the creation of a permanent establishment for tax purposes in connection with working from home. The changes are particularly relevant for companies whose employees regularly work remotely from abroad.
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