Year-End Transfer Pricing Tasks 2025/2026: Deadlines and Action Points for Companies

Year-End Transfer Pricing Review and Documentation: Pricing of Intercompany Transactions and Tax Compliance

Compliance with transfer pricing rules has been a key focus for tax authorities for several years. Companies must ensure that prices for intercompany transactions reflect arm’s length principles and must document them accordingly. Transfer pricing documentation is required at multiple levels:

• Master File at the group level,
• Local Files for domestic subsidiaries and transaction types,
• Country-by-Country Report (CbCR)for large multinational groups and their domestic subsidiaries.

Both domestic and international corporate groups must annually identify related parties and assess the arm’s length range for all intercompany transactions. If a transaction’s consideration falls outside this range, an adjustment should ideally be made before year-end. In addition to adjustments, a transfer pricing documentation obligation may arise.

Based on prior audit experience, tax authorities impose specific formal and content requirements for adjustments. Engaging a transfer pricing expert is highly recommended to avoid corrections based on the median value. Adjustments may impact multiple taxes, including corporate income tax, local business tax, and even the retail tax.

Transfer pricing documentation is mandatory only for transactions exceeding HUF 100 million calculated at arm’s length, although arm’s length principles apply to smaller transactions as well. Maintaining a record of sub-threshold transactions is advisable to demonstrate compliance. Since intercompany transactions can significantly impact operating results and profitability, tax authorities scrutinize them closely.

December 31, 2025 – Benchmark Review and Year-End Transfer Pricing Adjustments

As part of year-end transfer pricing tasks, it is critical to review previously applied benchmarks. Benchmarks, or market comparables used to determine intercompany prices, may become outdated or reflect changed market conditions. Legally, annual review and periodic re-preparation (every 3 years) are mandatory.

If the review reveals that transfer prices no longer meet arm’s length requirements, year-end adjustments should be made. These adjustments affect financial statements, results, and taxes payable.

By December 31, companies should:

• Review the relevance and accuracy of benchmarks,
• Conduct the legally required annual review,
• Adjust intercompany prices applied during the year if necessary,
• Prepare any year-end transfer pricing adjustments to ensure compliance during audits.

Expert review helps avoid median-based adjustments, reduces risks of tax base modifications, and ensures alignment with corporate tax, local business tax, and other relevant taxes.

December 31, 2025 – Year-End Deadlines for Transfer Pricing Documentation: Country-by-Country Report

The Country-by-Country Report (CbCR) is mandatory for multinational groups with consolidated revenues exceeding EUR 750 million. Typically, the ultimate parent company or another group member prepares the CbCR. The deadline aligns with the calendar year, i.e., December 31, 2025 for the 2025 fiscal year. Hungarian subsidiaries must also file a CbCR notification indicating which group entity will submit the report, and from which foreign tax authority the Hungarian NAV will receive the data. Failure, delay, or errors in this notification can result in penalties of up to HUF 20 million.

December 31, 2025 – Master File Deadline

The Master File provides a comprehensive overview of the group’s transfer pricing. Typically, it is prepared by the ultimate parent company, as they hold the required data. For calendar-year taxpayers, the Master File for 2024 must be available by December 31, 2025. If the Master File is prepared by the ultimate parent, the preparation deadline corresponds to the parent’s deadlines but must be submitted no later than the last day of the 12th month following the fiscal year. It is also advisable to review benchmarks by December 31, as any required adjustments may affect transfer prices, financial statements, and taxes.

May 31, 2026 – Transfer Pricing Documentation and Public CbCR Data Submission

Calendar-year taxpayers must submit their corporate income tax return by May 31, 2026, alongside transfer pricing documentation and the Master File.

From the 2023 tax year, transfer pricing documentation obligations include transfer pricing data reporting, submitted as part of the corporate tax return. The purpose is to provide the NAV with detailed information about intercompany transactions and pricing methods. Inaccurate or missing submissions may trigger penalties and targeted audits.

Public CbCR

The public Country-by-Country Report increases transparency by making multinational tax data publicly accessible. Unlike traditional CbCR for tax authorities, the public version shows how much tax companies pay in different countries, benefiting stakeholders, NGOs, investors, and the public.

The public CbCR applies to top-level parent companies under Hungarian accounting law with consolidated revenues exceeding HUF 275 billion over two consecutive financial years. The first affected year for calendar-year taxpayers is 2025, with a submission deadline aligned with the annual report, May 31, 2026.

Make Your Transfer Pricing Practices Transparent! LeitnerLeitner experts support all areas of transfer pricing: Benchmarking, Local File, Master File, CbCR, public CbCR, and related reporting. We provide end-to-end guidance from documentation preparation to meeting deadlines. Ensure your company’s compliance with the new transfer pricing and CbCR requirements – contact us today!

Glossary / Key Terms

• Year-End Transfer Pricing Tasks 2025/2026
  Year-end compliance and documentation duties for companies.
• Transfer Pricing Review
  Examination of intercompany pricing by tax authorities.
• Transfer Pricing Documentation
  Documentation proving compliance with arm’s length principles.
• Master File
  Group-level transfer pricing documentation.
• Local File
  Local-level documentation for domestic subsidiaries.
• Country-by-Country Report (CbCR)
  Multinational group reporting on profits, taxes, and economic activities per country.
• Public CbCR
  Public version of CbCR enhancing corporate tax transparency.
• Transfer Pricing Data Reporting
  Submission of transaction-level data to tax authorities.
• Benchmark Review
  Updating market comparables for arm’s length compliance.
• Year-End Transfer Pricing Planning
  Preparing adjustments and documentation before year-end.
• Corporate Tax Return
  Annual tax return, including transfer pricing disclosures.
• Multinational Corporate Group
  Interconnected companies operating across multiple countries.
• NAV Transfer Pricing Penalties
  Fines for missing or incorrect transfer pricing reports.
• Tax Transparency
  Clear and verifiable reporting of a company’s financial and tax activities.
• LeitnerLeitner Transfer Pricing Services
  Expert support for compliance, documentation, reporting, and deadlines.