The explosive growth of the digital economy in recent years has gone hand in hand with a radical transformation of the related regulatory environment. On the one hand, this has brought significant changes to civil and commercial law, consumer protection, competition and advertising law, data protection, criminal law, and other regulatory areas. On the other hand, electronic commerce conducted through digital platforms has posed numerous challenges for tax regulation, as tax authorities have long faced a significant information deficit regarding such transactions.

Milestones in the introduction of information exchange

One of the key tools for ensuring tax transparency has been the introduction of automatic exchange of tax information, implemented in two stages:

• Within the EU, platform operators have been obliged to report data under the DAC7 Directive since 2023, and the automatic exchange of such data started in 2024.
• In autumn 2025, the Hungarian Parliament approved three international agreements concluded within the OECD, including the agreement on automatic information exchange relating to digital platforms. This indicates that after 2026 the scope of information exchange will go beyond the EU framework, taking on a global dimension.

More effective action against international tax evasion

International data exchanges primarily aim to satisfy the information needs of national tax authorities. With the data received through these mechanisms, the tax authority is able to monitor transactions carried out by sellers on digital platforms more efficiently and in a more targeted manner. This supports voluntary compliance and also equips authorities with an effective tool to combat the shadow economy.

Information exchange affects not only tax authorities and platforms but also sellers. Sellers provide data to the platform, and the platform forwards the information to the tax authorities. The authorities subsequently exchange the data with each other, allowing the Hungarian tax authority to gain insight into revenues generated by Hungarian users (e.g. income from bookings on Booking.com), while also transmitting relevant data on foreign users to the competent foreign authority. To enhance the effectiveness of data exchange, both the platform operator may sanction sellers for failure to provide data, and naturally the tax authority may sanction the platform operator.

The Hungarian tax authority evaluates the received data and compares it with the information reported in Hungarian tax returns. Where discrepancies are identified, drawing on previous experience with international data exchange mechanisms, the authority may initiate a so‑called cooperative procedure, which is designed to encourage voluntary compliance. If the taxpayer fails to comply voluntarily, more severe consequences may follow, such as the initiation of a tax audit or the imposition of tax penalties.

Who is subject to the reporting obligation?

Data must primarily be reported to the Hungarian tax authority by platform operators with Hungarian tax residence, but the obligation also extends to EU‑residentplatform operators that are registered, have their place of effective management, or have a permanent establishment in Hungary. Third‑country businesses enabling the relevant activities may also choose to fulfil their reporting obligations in Hungary.

A platform operator is any entity that, by contracting with users, makes its platform – whether a website or a mobile application – available for users to connect with each other to sell goods or provide services, including any solution that enables the collection or payment of consideration relating to such activities. The term platform does not include software that exclusively enables payment processing, the display/advertising of the activity, or the redirection/transfer of users to another platform.

Which data and activities are covered by the obligations?

Platform operators must report data concerning users carrying out any of the following activities:

• rental of immovable property (residential, commercial, other properties, parking spaces),
• personal services (time‑ or task‑based work performed online or in person at the user’s request),
• sale of goods,
• rental of means of transport.

In relation to the above, digital platforms are subject to reporting, due diligence, data provision, notification, record‑keeping and document‑retention obligations.

The due‑diligence obligations of the platform operator include obtaining and verifying data from sellers qualifying as private individuals or entities (e.g. verifying tax numbers), determining tax residence, and obtaining property‑related information in the case of rental activities. In addition to seller data, the data report must include the number of transactions, the amount of consideration received, and, where applicable, details of the payment account used.

Platform operators bear enhanced responsibility for the proper fulfilment of reporting obligations. The Hungarian tax authority may impose a default penalty of up to HUF 2 million for failure to meet or properly perform a reporting obligation. A stricter measure available to the Hungarian tax authority is the removal of the platform operator from the official register for non‑compliance, and the tax authority may also decide to temporarily make the operator’s website inaccessible.

Globalising data reporting: information exchange beyond the EU

In this context, the OECD agreement entering into force after 2026 (DPI MCAA – Multilateral Competent Authority Agreement on Automatic Exchange of Information on Income Derived through Digital Platforms) is not an entirely new development, but rather an extension of the existing EU obligation to non‑EU countries. Consequently, international digital businesses will have to comply with both systems going forward.

Hungary signed the agreement on 26 November 2024, and the related act entered into force on 1 November 2025. The first mandatory data reporting will relate to the 2026 reporting year, due in 2027.

Under the DPI MCAA, digital platform operators – similarly to the EU system – must report user income primarily in connection with accommodation, transport and other personal services. However, data exchange may also extend to the sale of goods and the rental of means of transport. Signatory states automatically share this information with each other. Participating countries include, for instance, the United Kingdom, Canada, Norway, New Zealand and Argentina.

Special tax obligations imposed on digital platforms

Digital platforms can easily become hotspots for tax evasion, so in addition to data reporting, several special tax mechanisms aim to ensure the transparent operation of platforms. Most notably, these include VAT and retail tax rules. Both mechanisms treat platforms as deemed suppliers for tax purposes, imposing significant tax obligations on them.

Current and future VAT rules

VAT rules primarily affect distance sales, passenger transport and accommodation services conducted via platforms.

Since spring 2021, the Hungarian VAT Act has required platform operators facilitating distance sales of goods to be involved in VAT collection by treating them –through a legal fiction – as the purchaser and seller of the goods where they:

• facilitate distance sales of imported goods in consignments not exceeding EUR 150, or
• facilitate supplies of goods, irrespective of value, made within the EU by a non‑EU taxable person to a non‑taxable person.

This results in two supplies of goods (a chain transaction): one between the original seller and the platform, and another between the platform and the buyer. Platforms are required to account for VAT on transactions they facilitate and may do so via the One‑Stop Shop (OSS) system.

Looking ahead, the VAT reform officially adopted by the European Union on 11 March 2025 (ViDA – VAT in the Digital Age) contains important provisions concerning the platform economy. From 1 July 2028, platforms offering passenger transport or accommodation (e.g. Uber, Airbnb) will, in certain cases, become deemed VAT suppliers and therefore liable to pay VAT, especially where the original service provider is not VAT‑registered.

Member States may apply the deemed supplier rule differently or postpone implementation until 1 January 2030.

Retail tax

From 1 January 2025, both Hungarian and foreign platform operators are required to pay retail tax on retail activities carried out through digital platforms.

If the operator also engages in retail activities on its own account, that revenue also forms part of the tax base, although the actual payable tax will be reduced by the tax attributable to the operator’s own retail activity. Due to mid‑year tax law changes, the retail tax rate applicable to tax years beginning in 2025 and 2026 has significantly increased, furthermore, income thresholds have also shifted significantly.

Supervisory fee

From 2024, a special fee, the supervisory fee also applies to online platform operators established in Hungary. The fee must be paid to the Hungarian Media and Infocommunications Authority. The general rule sets the base of the fee at 0.3% of the previous year’s net turnover. Exemptions apply depending on company size or relatively low turnover.

Complying with the data reporting obligations of digital platforms and adhering to the special tax rules applicable to platform operators is a complex and demanding task, particularly given the numerous deadlines and the interplay of EU and international regulations. Should you require support with the related compliance work, our tax advisory team will be pleased to assist you.

This article provides general information and does not constitute advice.