New transfer pricing disclosure obligation

From January 1, 2023, a new disclosure obligation will apply to those taxpayers subject to transfer pricing documentation obligation. The new disclosure obligation shall be completed as part of the complemented 29 and 29EUD forms serving for the purposes of corporate income tax return.

Based on the modified National Economy Ministry Decree 32/2017., the annual corporate income tax returns will be complemented by a new disclosure for the purposes of optimizing the tax administration’s transfer pricing risk assessment processes.

The disclosure obligation, in line with the transfer pricing documentation obligations, will apply to such related party transactions the annual consolidated value of which reaches the threshold of a 100 million HUF.

What to know about the new transfer pricing disclosure:

  • The new disclosure cannot be or may not be fully completed without the transfer pricing documentation, therefore it is highly essential that taxpayers affected prepare the transfer pricing study in a timely manner, prior to submitting the corporate income tax return.
  • The report may be completed as part of the annual corporate income tax return forms, by using the 29 and 29EUD forms.
  • Since the disclosure is to be completed as part of the corporate income tax return, the respective deadline is the last day of the 5th month following the tax year, this is May 31 for taxpayers with a calendar business year.
  • In the case of an incomplete or missing disclosure, taxpayers raise their chances of undergoing tax audit.
Transfer pricing disclosure obligation

How can Forvis Mazars help you?

Since a relatively short time is available to prepare for the new disclosure, and a part of data to be shared is not clear or objective, please ask for the assistance and support of Mazars’s transfer pricing experts. We are happy to assist you in as follows:

  • Assistance in the identification of transactions subject to the disclosure,
  • Guidance in the interpretation of data and information to be shared,
  • Assistance in completing the necessary form,
  • Any other transfer pricing advisory.
Transfer pricing disclosure obligation

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Nagy Gabriella
Nagy Gabriella Head of International Transfer Pricing Center Budapest

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