When must related enterprises prepare transfer pricing documentation?

Related enterprises are required to apply the arm’s length principle when determining prices for transactions between them and, depending on the value of the transactions, they are also required to prepare transfer pricing documentation.

Segmentation – the greatest challenge of the new transfer pricing rules

One of the key challenges arising from the new transfer pricing regulation is the tightening of segmentation requirements. This is especially relevant for meeting transfer pricing obligations for the 2025 tax year, as this is a transitional year during which certain areas may already be subject to the new rules, while others must continue to be handled under the previous requirements.

 

Don’t leave your GloBE filing and reporting obligations due on June 30 until the last minute

The legal framework for implementing tasks related to the global minimum tax (GloBE) is continuously evolving. In recent months, several implementing regulations have been published. The autumn tax package refined the conceptual framework of the global minimum tax and the rules on information exchange. These provisions must be applied when fulfilling the obligations due on 30 June 2026, and since the rules are quite complex, preparation should not be postponed.

What R&D incentives are available in the Hungarian tax system and in the form of financial support?

In our previous article, we presented the changes in Hungarian economic support trends and clarified the basic concepts of R&D. In this article, we review the various available incentives. These can be grouped into three main categories: the first includes tax base and tax allowances that can be applied during research and development activities; the second category covers incentives related to the use of intellectual property created through these activities; and finally, R&D projects are also given preference in direct financial grant funding.

The new transfer pricing regulation brings relief for smaller businesses, while imposing even stricter requirements on larger ones.

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.