Year-End Transfer Pricing Checklist

Transfer pricing has become one of the most significant tax risk areas for businesses. At the same time, the Hungarian Tax Authority (NAV) is using increasingly sophisticated audit tools to scrutinize transactions between related parties, while new rules coming into force from 2026 further tighten compliance requirements.

Don't Leave Transfer Pricing Tasks Until the Last Minute!

Although detailed transfer pricing documentation and reporting are mandatory only for related-party transactions exceeding HUF 150 million, the arm's length principle must also be applied to transactions below this threshold.

As transfer pricing regulations are becoming increasingly complex, preparing the necessary data and analyses can be time-consuming. Companies should ensure that they have an adequate financial and database infrastructure in place, obtain the required information from foreign related parties on time, and prepare the necessary functional and benefit analyses.

Review Before Year-End

Check:

·        the adequacy and up-to-dateness of your transfer pricing processes and internal policies;

·        the appropriateness of your financial segmentation;

·        the validity and timeliness of your benchmark studies;

·        the list of transactions that may become subject to transfer pricing documentation requirements.

What Can the LeitnerLeitner Transfer Pricing Team Offer You?

·        Comprehensive transfer pricing support and end-to-end compliance assurance

·        Leadership with former NAV transfer pricing expertise

·        Tailor-made services instead of a one-size-fits-all approach

·        Premium-quality advice based on the latest developments

Benchmark Review and Adjustments Before Year-End

Benchmark studies must be renewed every three years and updated annually. If the results indicate that the transfer prices applied during the year deviate from arm's length levels, adjustments may be required before year-end.

NAV also places special emphasis on the use of domestic comparable data when determining arm's length prices for activities carried out in Hungary.

Important Transfer Pricing Deadlines

31 December 2026

·        Annual review of benchmark studies;

·        Preparation of any necessary transfer pricing adjustments;

·        Hungarian members of multinational enterprise groups with consolidated revenues of at least EUR 750 million must notify the tax authority by the end of the tax year, i.e. by 31 December 2026, which group entity will file the 2025 Country-by-Country Report (CbCR). Incorrect, incomplete or late reporting may result in substantial penalties;

·        Obtaining the group-level Master File for the previous tax year from the parent company. If the parent company does not prepare the Master File by the applicable deadline, the Hungarian subsidiary must ensure that the documentation is completed.

Although the end of the tax year may still seem far away, it is advisable not to postpone transfer pricing tasks until December. Timely reviews, documentation and, where necessary, transfer pricing adjustments can not only help avoid penalties but also significantly reduce the risks associated with a tax audit.

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Year-End Transfer Pricing Tasks: Avoid Unnecessary Transfer Pricing Risks and Penalties with This Checklist