Hungarian Group Taxation to Counterbalance the Tightening Transfer Pricing Documentation Rules

A new corporate tax grouping concept was introduced in Hungary as of 2019 with the aim of easing transfer pricing documentation burdens. This article highlights some of the peculiar features of the new Hungarian group taxation rules and gives an overview of some of the practical aspects of the transfer pricing documentation rules implemented in Hungarian legislation as of 2018. The analysis focuses on the interrelationships between these transfer pricing rules and the new group taxation rules, and highlights their shortcomings and the opportunities they offer.