Hungarian summer tax package 2025 adopted

On 11 June 2025, the Hungarian Parliament adopted the Hungarian summer tax package 2025, which introduces significant amendments across various areas of the Hungarian tax system, including corporate tax, global minimum tax, VAT and personal income tax. Below we summarise the most important details for decision makers.

Corporate tax

• Preferential transfer of assets: The Hungarian summer tax package 2025 clarifies the conditions for tax deferral. If the shareholding requirement is only partially unmet, only the corresponding part of the previously deferred gain will become taxable, proportional to the transferred participation falling outside the affiliated group. The acquiring company must calculate the tax base differently in such cases.

• Corporate spin-off: This qualifies as a preferential transfer of assets for corporate tax purposes, thus allowing deferral and exemption from duties and excluding transfer pricing obligations.

• Reported shares: Following clarification, the participation exemption rules  will also apply to cross-border transformations occurring after the promulgation. If the taxpayer became a Hungarian tax resident due to a transformation completed in 2024, the benefit still applies provided all legal conditions (e.g., notification within 75 days) are met.

• IFRS-based taxation: The tax base calculation for corporate tax under IFRS is clarified. For derecognition of  own shares or participations (including in-kind contributions), the pre-tax profit must be adjusted for related profits or losses from the current and the previous tax years.

• R&D tax relief: The HUF 50 million limit on the tax base allowance for the direct costs of research and development activities carried out jointly with higher education institutions, the Hungarian Academy of Sciences and certain other research institutions is raised to HUF 150 million.

All corporate tax-related provisions of the Hungarian summer tax package 2025 take effect the day after promulgation.

Global minimum tax

• Notification of supplementary taxpayer status: The deadline is now the last day of the second month following the tax year-end (e.g. for the calendar year 2025: 28 February 2026).

• Default penalty: Violation of GloBE data reporting obligations may result in a fine of HUF 10 million by the Hungarian tax authority.

• Passive accrual: The anticipated supplementary tax for a financial year must be accounted for as a passive accrual, to comply with the matching principle. This rule already applies to reports for financial years starting in 2025.

Value added tax

• E-cash registers: Mandatory real-time receipt data reporting is postponed from 1 July 2025 to 1 September 2026. Voluntary use of e-cash registers is permitted from 1 July 2025, and related reporting obligations already apply from that date. The package also specifies technical and procedural requirements.

• Customs representative declaration: From 1 October 2025, customs representatives must declare the tax base and VAT amount in order to exercise the right to deduct VAT transferred to them.

• Travel services: From 1 January 2026, VAT base and tax amounts need not be indicated on invoices (unless the customer is a taxable person declaring non-travel organizer use). This does not apply to online reporting.

• Natural gas sales: From 1 January 2025, reverse charge VAT applies to gas sales between domestic taxable dealers. From 20 July 2025, buyers must declare their taxable dealer status. Both parties are subject to data reporting, including MWh volume.

• Online invoice data reporting: From 1 January 2026, successor-issued invoices must include the predecessor’s tax number. For VAT groups, both the group and the participating member’s tax numbers must be reported.

• Payment service provider reporting: The opening or closure of a payment account must be reported to the Hungarian tax authority within 7 days instead of 15.

• Chain transaction audits: From promulgation, the audit period is extended where multiple taxpayers must be audited to establish VAT liability (e.g. up to 365 days for reliable taxpayers).

Personal income tax

• Mothers’ allowance: The Hungarian summer tax package 2025 includes a number of technical changes related to the allowance for mothers of two and three children.These clarify the order of applying allowances, update prepayment declarations and regulate monthly tax return data. Infant care benefit (csed) and child care benefit (gyed) become tax-exempt with this new allowance.

• Expansion of tax-free benefits: From promulgation, tax exemption for employer-provided housing (e.g. service apartments, workers’ accommodation, dormitories) extends to foreign employees housed at Hungarian branches of foreign companies, provided legal conditions are met.

• Private use of electric bicycles: From 1 January 2026, tax exemption extends to electric bicycles up to 750 W (previously 300 W) when provided for private use by the employer.

Social contribution tax

From 1 January 2026, a new tax obligation arises for employers paying income to pensioners claiming PIT allowances for dependent children. The tax applies if total income exceeds four times the average annual wage and the payer would otherwise be required to withhold advance tax. Related entities are considered a single payer.

Tax procedure rules

• Conditional tax rulings: From 1 August 2025, pre-consultations may be requested online for a HUF 1 million fee. Regular rulings cost HUF 10 million, urgent ones HUF 14 million, standard contract rulings HUF 12 million, and combined urgent/contract rulings HUF 16 million.

• Procedures to determine arm’s length prices: From the 31^st day after promulgation, fees increase to HUF 10 million (unilateral) and HUF 14 million (bilateral/multilateral). Pre-consultation costs rise to HUF 1 million per session.

• Branch registration: From promulgation, taxpayers must report the name and tax number of their Hungarian branches to the tax authority.

• Delisting from negative lists: Employers may apply once a year for removal from certain public negative lists of the Hungarian tax authority if no more than five employees were unreported and the related fine is paid in time.

• Automatic payment relief: Thresholds for eligibility increase for reliable taxpayers and both natural and legal persons, regardless of taxpayer classification.

Duties

From the 31^st day after promulgation, property value corresponding to a solar or wind power installation is exempt from transfer duty.

Special tax on credit institutions and financial enterprises

The special tax on credit institutions and financial enterprises continues in 2026. Tax is based on the 2024 pre-tax profit, adjusted as specified. Rates: 8% up to HUF 20 billion (7% in 2025), and 20% above (18% in 2025). The allowance for increasing the stock of government bonds is still available.

Income tax for energy suppliers

The income tax rate for energy suppliers is set at 41% in 2025 and 31% in 2026.

Additional insurance tax

The additional insurance tax liability will remain for the tax year starting in 2026, but the amount of the allowance will be increased from 30% to 60% of the increase in the nominal value of the government bonds portfolio.

Accounting

The entry into force of sustainability reporting obligations is postponed by two years.

In this article, we have tried to provide a thorough summary of the most important parts of the Hungarian summer tax package 2025 that affect companies’ decision makers. If you have any questions about the changes detailed here, please contact the tax consulting team of WTS Klient Hungary who are always at your disposal.

This article provides general information and does not constitute advice.