Since the introduction of transfer pricing documentation requirements in 2003, the Hungarian tax authorities have devoted special attention to auditing the prices charged in transactions between associated parties, and the number and depth of assessments has been constantly increasing.

It has become a common experience for taxpayers to have tax inspectors meticulously review their transfer pricing documentation, its contents, and the technical accuracy of the conclusions and assumptions therein during general tax audits. Some tax inspectors have completed transfer pricing training in recent months, and the tax authorities already have access to (and use during audits) the AMADEUS database, one of the starting points of complex transfer pricing audits. Furthermore, an increasing number of tax inspectors understand and apply the transfer pricing guidelines developed by the OECD.

This implies that all skills and tools are available to the tax authorities to meaningfully audit whether transfer prices charged are in line with the arm's length principle.