The new transfer pricing decree has entered into force

On 23 January 2026, Decree 45/2025 of the Ministry for National Economy (NGM) on transfer pricing documentation and transfer pricing data reporting entered into force.

Compared to the draft decree previously issued for public consultation, the legislator clarified certain wording and introduced the following substantive changes:

• Documentation may now be prepared in German, in addition to English and Hungarian.
• Regarding the benchmarking studies, in the case of a foreign tested party, the final text sets less strict requirements for defining the geographical criteria.
• Taxpayers may decide separately for each type of intercompany transaction whether they apply the previous or the new decree’s requirements for financial years starting in the 2025 calendar year.

Apart from the above, it can be concluded that the content of the final decree corresponds to the draft text published for public consultation, details of which can be found in our previous newsletter.