Amendment of the Accounting Act and the Accounting Treatment of Transfer Pricing Adjustments

Act LXXXIII of 2025 – practical guidance for companies 

The tax package, published on 19 November 2025 with the aim of reducing administrative burdens and ensuring legal harmonisation, introduces significant changes in the accounting treatment of transfer pricing adjustments. Sections 105–107 of Act LXXXIII of 2025 stipulate that the difference between the arm’s length price under the Corporate Income Tax Act and the actual consideration applied – i.e. the TP adjustment – must also be recognised in the books. This brings the year-end lump-sum tax base adjustment, recorded with an accounting voucher, and the financial statements closer together, reducing interpretative uncertainties. 

Why was the amendment necessary?

Until now, most transfer pricing adjustments appeared only in the tax base, and not all changes were reflected in accounting. This discrepancy arose mainly in the case of year-end, one-off TP adjustments. The legislator’s intention was therefore to ensure transparency and consistent data reporting: if a company subsequently modifies the consideration applied to a related-party transaction, this must be reflected both in the tax and accounting records. 

The amendment enters into force on 1 January 2026 and is mandatory for financial years starting in 2026. However, it may also be applied to financial statements relating to the financial year starting in 2025. 

What exactly has changed?

If the price of a transaction is subsequently modified based on the parties’ agreement, the TP adjustment must be recorded in the books by the balance sheet preparation date. The adjustment may affect the following items: 

• acquisition cost of assets – Accounting Act Section 47 (10) 

• net sales revenue – Accounting Act Section 73 (4) 

• costs and expenses relating to services received – Accounting Act Section 78 (8) 

A significant simplification is that in the case of a voluntary arm’s length price adjustment, it is not mandatory to adjust to the median; the correction may be recorded anywhere within the arm’s length range. 

Why is this important in practice?

Section 18 of the Corporate Income Tax Act remains clear: all related-party transactions must be carried out at arm’s length. The amendment to the Accounting Act reinforces this requirement, meaning that companies must: 

• ensure consistency between tax base adjustments and accounting data, 

• support year-end TP adjustments with unified documentation, 

• take advantage of the flexibility of choosing any point within the arm’s length range, without a median requirement. 

It should be emphasised that although transactions below the HUF 100 million threshold may be exempt from transfer pricing documentation and reporting requirements, the obligation to comply with the arm’s length principle applies to all related-party transactions. This means that the TP adjustment — and thus the accounting recognition — is also mandatory for transactions below the threshold, regardless of documentation requirements. 

If you would like to determine the arm’s length range by the balance sheet preparation date, or assess how the amendment affects your company, or review the accounting and tax requirements applicable to year-end TP adjustments, our expert team is ready to assist.