On December 23, 2025, Hungary enacted Decree No. 45/2025, setting new transfer‑pricing documentation thresholds. The decree requires local files for related‑party transactions above 150 million HUF and master files for those above 500 million HUF, while offering simplified documentation for low‑value services.
Transactions at usual market price exceeding 150 million Hungarian forints (US$452,196) in the tax year require a local file.
When the total net value of a related‑party transaction priced at arm’s length exceeds 500 million Hungarian forints (US$1.5 million).
Yes, for taxpayers providing low‑value added services, subject to conditions.
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Bloomberg Tax · 2 days ago
The European Court of Justice ruled in Case T-363/25 that VAT deductions cannot be claimed on re-invoiced supplies when the underlying transaction structure is deemed fictitious. A Hungarian automotive parts trader was denied input VAT deduction on purchases from German suppliers re-invoiced through a domestic intermediary.
Macfarlanes · about 1 hour ago
The UK Supreme Court ruled on 15 January 2026 that VAT on professional costs incurred in connection with a VAT‑exempt share disposal is not recoverable, rejecting any general fundraising exception. The decision applies to corporate groups where the parent provides taxable management services to a subsidiary, confirming that share sales remain within the scope of VAT but exempt, and that VAT grouping does not alter this treatment. Taxpayers must therefore plan for non‑recoverable transaction costs when restructuring or disposing of subsidiaries.
Bloomberg Tax · about 1 hour ago
An Advocate General for the European Court of Justice has opined that transfer price adjustments made by Stellantis Portugal to dealership sales are not subject to VAT, as they are considered alien to VAT law. The opinion, issued Thursday, is not binding on the court, and the ECJ decision remains unscheduled. The case centers on Stellantis's retroactive price adjustments to ensure a basic profit margin for local dealerships.
VatCalc · about 3 hours ago
The Austrian government will cut the VAT rate on a basket of essential food items from 10% to 5% starting 1 July 2026, a move aimed at easing inflationary pressures. The measure was confirmed on 14 January 2026 and will be counter‑financed by fees on imported parcels from third‑country suppliers such as China.
LinkedIn · about 4 hours ago
Advocate General Kokott’s Opinion C‑603/24 clarifies how intra‑group transfer price adjustments interact with VAT. The opinion states that such adjustments are not automatically a separate VAT supply, but may alter the taxable amount under Articles 73 and 90 of the VAT Directive if they reflect a variable purchase price agreed upfront. Only when an actual service for consideration exists is a separate supply considered.
SII Spain · about 7 hours ago
Spain has postponed the implementation of the Verifactu Ordinance to 2027, extending the original July 2025 deadline. An extraordinary opt‑out window for voluntary SII participants runs from 26 December 2025 to 31 January 2026, allowing withdrawal via Form 036/037 effective 1 January 2026. The decree also clarifies that mandatory SII participants cannot opt out and that non‑compliant invoicing software cannot be sold after 29 July 2025.
