The bills submitted on 27 October 2026 already provide an outline of the most significant changes included in the Hungarian autumn tax package 2026. Although certain provisions may still be amended during the parliamentary process, the current wording of the proposals is expected to largely determine the direction of the tax rules applicable from 2027. It is therefore worth preparing in time. Below, we summarise the most important business-related elements of the draft Hungarian autumn tax package 2026.
Corporate income tax
New corporate income tax regime for large enterprises and a higher tax rate
Based on the draft Hungarian autumn tax package 2026, a separate corporate income tax regime would apply to large enterprises from 1 January 2027. As a general rule, a company would qualify as a large enterprise if its revenue in the second year preceding the tax year reached the equivalent of EUR 500 million. In certain cases, however, taxpayers would also be allowed to opt for this status. Large enterprises would become subject to a 15% corporate income tax rate instead of the current 9% rate. In parallel, the determination of the tax base would change significantly and, in several respects, would move closer to the logic of the global minimum tax regime. At the same time, the payable tax could be reduced by 85% of the local business tax, but by no more than 25% of the calculated corporate income tax liability.
Stricter rules for corporate income tax groups
The proposal would also fundamentally reshape the conditions for group corporate taxation. In the future, a new tax group could primarily be established by businesses that:
- belong to the same consolidation group,
- have the same balance sheet date, and
- apply the same accounting standards.
An important additional rule is that where even a single member of the group qualifies as a large enterprise, all members of the tax group would be required to determine their tax base according to the special rules applicable to large enterprises.
Transformation of the regime for reported participations
The draft would limit the current tax benefits associated with reported participations by introducing the concept of “qualified participation” instead of the current definition. From 1 January 2027, favourable tax treatment would generally apply only to participations of at least 10% at the time of derecognition, while the reporting obligation currently required to obtain the tax incentive would be abolished. Capital gains and losses realised on qualified participations held for at least one year, as well as impairment losses relating to such participations, could be eliminated from the tax base through tax base adjustment items. However, the previous rules would continue to apply to participations that:
- were reported under the former rules, and
- do not qualify as qualified participations at the time of derecognition.
Renewal of R&D incentives
Several favourable amendments are expected for companies carrying out research and development activities in relation to R&D projects and eligible costs incurred in projects commenced on or after 1 January 2027. According to the draft Hungarian autumn tax package 2026, for example:
- payable corporate income tax could be reduced by 20% of eligible R&D costs instead of the current 10%;
- where the tax base allowance is applied, personnel expenses related to researcher-developer employees and depreciation of tangible assets used in in-house R&D activities could be recognised at twice their amount as eligible costs;
- the mandatory five-year commitment linked to the election of the tax incentive would be abolished.
The legislation would also allow taxpayers to apply both the tax incentive and the tax base allowance within the same tax year, determined separately on a project-by-project basis. At the same time, for purchased R&D services, the range of companies and institutions whose services may be recognised as eligible costs would be narrowed.
Tighter rules for development tax allowances
The rules governing development tax allowances would be tightened in several respects:
- the general investment threshold would increase from HUF 3 billion to HUF 5 billion;
- several investment categories would be abolished;
- besides the previously known headcount maintenance requirement, new detailed conditions regarding increases in own-activity R&D expenditure would be introduced for large enterprises.
Additional important changes include:
- the maximum amount of the allowance that may be utilised would decrease from 80% of the calculated tax to 70%;
- the utilisation period would be reduced from 12 years to 10 years;
- taxpayers would also be required to comply with specified environmental protection and occupational safety requirements in order to claim the allowance.
The new rules would apply to investments notified and commenced on or after 1 January 2027.
The tax allowance available for investments aimed at ensuring manufacturing capacity for clean technologies would also be restricted. Under the draft Hungarian autumn tax package 2026, the allowance would only be available for investments with a present value of at least HUF 100 million.
Tax incentive for sports sponsorship to be phased out
According to the proposal, the existing corporate income tax incentive scheme related to the support of spectator team sports would be abolished. Tax incentives under this title could be based only on support payments transferred by the end of 2026, and the related tax incentive could be claimed no later than in the corporate income tax return submitted before 1 July 2029. Instead of the previous tax incentive, the tax base could be reduced by 20% of the amount granted exclusively for the support of amateur sports.
Transfer pricing reporting: separate form and greater autonomy
If Parliament adopts the proposed Hungarian autumn tax package 2026, transfer pricing reporting will no longer be submitted as part of the annual corporate income tax return but on a separate reporting form. The amendment would enter into force on 1 January 2027 and, at the taxpayer’s discretion, could first be applied to reporting obligations relating to the 2026 tax year. With the introduction of standalone transfer pricing reporting, a question arises as to whether subsequent amendments to the reporting will be subject to procedural rules different from those applicable to ordinary tax return corrections.
Innovation contribution
Rate may increase to 0.5%
According to the legislative proposal, the rate of the Hungarian innovation contribution would increase from 0.3% to 0.5% as of 1 January 2027, while the rules for determining the contribution base would remain unchanged.
The higher rate would already have to be applied when determining contribution advances for the first half of the 2027 tax year. If a taxpayer has already submitted its return on advances for the first half of 2027 by 31 December 2026, the Hungarian tax authority (NAV) would determine the amended advance amount by resolution by the last day of the second month of the 2027 tax year. Contribution advances payable for the second half of 2027 and the first half of 2028 would likewise have to be calculated using the 0.5% rate.
Energy suppliers’ income tax
New tax base adjustments may be introduced
The amendment to the Hungarian District Heating Act would introduce new tax base adjustment items. The tax base would be increased, among others, by:
- impairment recognised on equity interests (which could only be recognised for tax purposes upon derecognition from the books),
- interest expense and transfer pricing adjustments related to loans and other financing liabilities received from related parties.
At the same time, subject to certain conditions, the tax base could be decreased by:
- the reversal of impairment,
- the derecognition of the participation.
Energy suppliers qualifying as large enterprises or opting for the large enterprise corporate taxation regime would also be required to apply the new corporate income tax rules accordingly. The tax advance for 2027 would have to be determined based on the expected annual tax liability, while any difference would need to be declared and paid quarterly.
Global minimum tax (GloBE)
Simpler administration and more flexible penalty rules
With respect to the global minimum tax, the legislative proposal primarily contains clarifications:
- It clarifies that, for the transitional year, taxpayers have 18 months not only to file the return but also to pay the tax.
- For purely Hungarian corporate groups, the separate reporting obligation would be abolished, and taxpayers would be able to fulfil this requirement within their tax return.
- From the day following promulgation, the provision requiring taxpayers to report the structure of the corporate group and the ownership interests of individual group members in other group members would be repealed. In practice, the return has not provided an opportunity for such reporting so far either.
Under the proposal, the tax authority would have discretionary powers when imposing default penalties. The previously mandatory penalties of HUF 5 million and HUF 10 million would in the future represent only the maximum amount of the penalty that may be imposed.
The list of countries participating in the information exchange agreement related to the global minimum tax would be expanded to include Hong Kong.
Based on the OECD guidance published in September 2026, the draft Hungarian autumn tax package 2026 clarifies the applicable financial accounting standard. Where the local financial year differs from that of the multinational group, the Hungarian accounting standards may be applied if the group-level financial statements include the data of the Hungarian financial statements. The same rule applies where the consolidated financial statements are prepared using Hungarian financial data despite the different balance sheet date.
Where Hungarian group entities prepare their financial statements in different currencies, the multinational group would be required to calculate the Hungarian minimum top-up tax using the currency applied within the group, based on a five-year election.
Small business tax
R&D tax incentive may increase fourfold
The legislative proposal would significantly increase the R&D tax incentive available under the Hungarian small business tax. Instead of the current 50% of wage costs recognised as direct costs of R&D activities, 200% of such wage costs could be claimed as a tax incentive.
Sustainability reporting
Scope of affected companies would be significantly reduced
The rules of the CSRD (Corporate Sustainability Reporting Directive) would be substantially simplified from 1 January 2027. The reporting obligation would apply only to the largest companies that, in each of the previous two financial years:
- exceeded HUF 180 billion in net sales revenue, and
- employed an average of more than 1,000 employees.
As a result, many businesses could already be exempt from reporting requirements for the 2026 financial year.
The burden of value-chain-related reporting would also be reduced:
- companies with fewer than 1,000 employees could refuse to provide information beyond the scope prescribed by law,
- certain sensitive information could be omitted from sustainability reports.
In addition, Hungarian branches of EU companies would no longer be required to prepare separate reports if the relevant information is already included in the report of the parent company.
At the same time, collecting sustainability-related data may remain justified due to ESG regulations, financing requirements and reporting obligations within corporate groups.
Value added tax (VAT)
E-VAT system: six-month postponement and gradual introduction
From 1 July 2027 (six months later than previously planned), the mandatory use of the Hungarian e-VAT system for filing VAT returns will begin. In the first phase, the obligation will apply to Hungarian taxpayers with the largest tax performance that are required to submit monthly VAT returns, and from 1 January 2028 it will generally become mandatory for all taxpayers. In limited cases, filing VAT returns on traditional forms will remain possible.
In our article Hungary’s tax authority takes major step toward digital transformation, we explain the details of the phase-out of the General Form Completion Program (ÁNYK), which is now widely used for the submission of tax returns. Our article M2M VAT return: New dimension of VAT digitalisation in Hungary presents the options available to businesses for filing VAT returns after the phase-out of the ÁNYK program.
Possibility to self-revise previous returns remains: The amendment ensures that VAT returns originally submitted on traditional forms may continue to be self-revised in the same manner after 1 July 2027.
Transaction-level reporting of EU transactions: Since transaction-level reporting will be implemented within the e-VAT system, future EC Sales Lists for intra-Community transactions may also be submitted on a transaction-by-transaction basis.
Reverse charge mechanism and 5% VAT rate on residential property
Under the amendment, the reverse charge mechanism will remain in place for transactions for which its applicability would otherwise have expired on 31 December 2026. Consequently, no changes are expected regarding products and transactions subject to Hungarian reverse charge VAT.
By repealing the previous sunset provisions, the amendment ensures the continued applicability of the 5% VAT rate on the sale of new residential properties without any final expiry date.
We discussed the preferential VAT rate in detail in our article 5% VAT on homes: the extension is drawing to a close.
Changes affecting intra-Community transactions
Under the draft Hungarian autumn tax package 2026, the application of VAT deduction rights for intra-Community acquisitions of goods would become simpler. According to the proposal, taxpayers would no longer be entitled to deduct VAT exclusively in the tax period in which the corresponding output VAT must be assessed. This provision is expected to be applicable, within the limitation period, even with respect to periods preceding its entry into force.
In line with changes to the ViDA (VAT in the Digital Age) rules, the call-off stock simplification scheme will be abolished from 1 July 2029. Since the simplification applies to goods transferred and subsequently sold from call-off stock within 12 months, the old rules may be applied for the last time to goods transferred to another Member State no later than 30 June 2028. The related record-keeping and EC Sales List reporting obligations will also be phased out.
Extended deemed supplier role of platforms: From 2027, the deemed supplier status of platform operators will apply not only to sales to private individuals but also to import transactions made to certain taxable persons that, due to their special status, are not liable for VAT on intra-Community acquisitions (e.g. VAT-exempt small businesses or taxpayers carrying out only exempt activities without a right to deduct VAT).
Clarifications and harmonisation of one-stop-shop (OSS) rules:
- The amendment clarifies that the EUR 10,000 threshold simplification available to small businesses (allowing VAT obligations to be fulfilled in the Member State of establishment) can only be applied if the goods are dispatched from the Member State in which the supplier/service provider is established.
- The scope of the non-Union OSS scheme will be expanded from 2027. The scheme will become available for a broader range of OSS-covered services supplied within the EU, reducing VAT registration obligations for non-EU service providers in multiple Member States.
- From 1 January 2027, the Union OSS scheme will be extended to certain supplies of natural gas, heating energy, cooling energy and electricity to final consumers, including, for example, the charging of electric vehicles.
To harmonise VAT payment rules concerning transactions reported through the Union and non-Union OSS schemes, Member States may not define the chargeable event at a date other than the date of supply. Consequently, special time-of-supply rules for periodic transactions will not apply within the OSS framework.
Taxpayers providing intra-Community passenger transport services will be exempt from the receipt issuance obligation from 2027.
Deadline for receipt data reporting to be extended
As an administrative simplification measure, the deadline for reporting manually issued receipts will increase from 3 days to 7 days from 2027.
We discussed the reporting requirements in detail in our article Mandatory receipt data reporting in Hungary from September.
Excise duty
In deviation from the general indexation rules, excise duty on high-alcohol-content spirits (such as vodka, whisky, rum, gin and pálinka) and intermediate alcoholic products, including certain liqueurs and vermouths, would increase by 12%. In addition, the tax burden on cigars and cigarillos would increase significantly, as both the excise duty rate and the minimum tax amount would be raised.
In light of high fuel prices, the 2027 indexation of excise duty rates on premium fuels (petrol and diesel) and kerosene would be postponed until 1 July 2027.
A favourable development for smaller tax warehouses is that, from 1 January 2027, the threshold triggering the obligation to pay excise duty advances would increase from HUF 6 million to HUF 12 million.
Customs administration
The proposal introduces technical amendments to the rules governing the rounding of customs duties and also repeals the provisions concerning customs adviser and customs broker certificates.
Personal income tax and family benefits
Exit tax: new tax for individuals relocating abroad with significant financial wealth
The legislative proposal would introduce an exit tax from 1 January 2027 for individuals with long-term Hungarian tax residency and substantial financial assets who transfer their tax residence abroad.
We discussed the details of the exit tax in our article Hungarian exit tax for individuals is coming!
Introduction of a tax credit
According to the draft Hungarian autumn tax package 2026, Hungary’s flat-rate personal income tax system would effectively cease to exist from 2027. For employment income up to the amount of the statutory minimum wage, a 6% tax credit could be claimed against the 15% personal income tax liability, resulting in an effective personal income tax burden of 9% on income up to the minimum wage level. For employment income exceeding the minimum wage, the amount of the tax credit would gradually decrease and would be phased out at around twice the amount of the minimum wage.
The tax credit would apply to employment income. However, it would not be available for:
- severance payments,
- fees under service contracts,
- rental income from real estate,
- entrepreneur’s withdrawals,
- income taxed under the simplified contribution to public revenues (Hungarian abbreviation: ekho) regime.
Although the tax credit would not apply to ekho-taxed income, individuals earning both ekho income and employment income could still claim the tax credit on the latter. At the same time, income taxed under the ekho rules must also be taken into account when determining the amount of the tax credit.
Complete overhaul of the calculation of personal income tax allowances
The current system of personal income tax allowances linked to the tax base would be transformed into a system of tax allowances that directly reduce the calculated tax liability. While the eligibility conditions would remain largely unchanged, existing tax base allowances would be converted into direct tax allowances , significantly changing the calculation methodology.
The order in which tax benefits may be claimed would also change. Following the application of the tax allowance, the following benefits would be available in this order:
- tax benefits available to mothers,
- personal tax allowance,
- first-married couples’ allowance,
- activity-related tax allowance,
- family tax allowance.
Any unused portion of the family tax allowance could continue to be claimed as a family contribution allowance.
Tax allowances: new form, unchanged eligibility
The legislative proposal would determine the amount of tax allowances directly in Hungarian forints.
The tax allowance for individuals under the age of 25 would remain available in the form of a tax allowance.
The personal allowance would also remain available, but as a direct tax allowance instead of a tax base allowance.
Under the proposal, the allowance for first-married couples would remain unchanged. As under the current rules, the benefit would amount to HUF 5,000 per month, but would become available as a tax allowance instead of a tax base allowance. The eligibility conditions would remain substantially unchanged.
The family tax allowance system would be significantly transformed from 2027. Instead of a tax base allowance, entitled individuals could claim a direct tax allowance in the following amounts per dependent child:
- HUF 20,000 per month for one child,
- HUF 40,000 per month per child for two children,
- HUF 66,000 per month per child for three or more children.
An additional HUF 20,000 per month tax allowance would be available for dependants who are permanently ill or severely disabled.
Eligibility conditions and the main rules regarding the sharing of the benefit would remain unchanged. If an individual’s tax liability is insufficient to utilise the full amount of the tax allowance, the remaining amount may continue to be claimed as a family contribution allowance.
Transformation of tax allowances available to mothers and introduction of an income cap
According to the proposal, the tax benefits currently available to mothers of three children and mothers of four or more children would be merged. The new allowance for mothers raising three or more children would provide lifelong full personal income tax exemption on employment income up to a gross amount of HUF 1 million per month.
Mothers of two children would be entitled to personal income tax exemption on employment income up to a gross monthly amount of HUF 1 million until the end of the year in which they reach the age of 40. A gross monthly income cap of HUF 1 million would also be introduced for the existing personal income tax exemption available to mothers under the age of 30.
Under the amendment, the previously planned personal income tax exemption for all mothers of two children would not be implemented, and the exemption would only remain available within the scope described above.
Family allowance doubled, social security benefits incorporated into legislation
Under the draft Hungarian autumn tax package 2026, affected families would receive double the current amount of family allowance from 2027. The higher amount would first be paid in January 2027 in respect of the December 2026 entitlement period.
The following benefits would be incorporated into the Personal Income Tax Act as tax-exempt income categories and would therefore be expressly excluded from the consolidated tax base:
- infant care benefit (CSED),
- child care benefit (GYED),
- adoption benefit.
The family contribution allowance would continue to be available against the pension contribution payable on GYED.
Amendments to administrative and procedural rules
To align with the new tax benefit system, new rules on tax advance declarations, social security contribution allowances and tax return filing procedures would be introduced.
Reduction of tax exemption for business lunches and representation expenses
Under the current rules, part of the costs of business lunches held in restaurants or confectioneries is exempt from personal income tax and social contribution tax. The exemption would continue to apply up to 1% of the company’s revenue; however, the annual cap would be reduced from HUF 100 million to HUF 50 million.
Wealth tax
Unchanged tax burden, refined valuation rules
According to the draft Hungarian autumn tax package 2026, the key parameters of the planned Hungarian wealth tax from 2027 would remain unchanged. Net wealth exceeding HUF 1 billion would remain subject to taxation at rates of 1% and 1.5%.
The submitted bill primarily refines the valuation rules for various asset classes:
- the valuation methodology for listed and unlisted shareholdings would change,
- the special rules applicable to holding companies could be extended,
- the scope of properties covered by NAV’s real estate valuation model would be expanded.
In addition, more detailed provisions would apply to foreign real estate and indirect ownership of Hungarian real estate. The liability of property valuers would be tightened, and tax return submission would be linked to a dedicated electronic platform.
We discussed the changes in detail in our article Wealth tax: important changes in wealth valuation in Hungary.
Rehabilitation contribution
Burden on large enterprises may increase significantly
The proposal would substantially increase the rehabilitation contribution payable by larger businesses. This public levy must be paid by employers whose ratio of employees with reduced work capacity does not reach 5%. Under the 2026 rules, employers must pay an amount equal to nine times the minimum wage, currently HUF 2,905,200 annually, for each missing employee.
The contribution would increase to:
- 11 times the minimum wage for employers with at least 250 employees,
- 13 times the minimum wage for employers with more than 500 employees,
- 15 times the minimum wage for employers with at least 1,000 employees.
For the largest companies, this would represent a 66.7% increase in burden compared to the current rules.
Advertisement tax
Progressive taxation may return from 2027
According to the legislative proposal, advertisement tax would be reintroduced from 1 January 2027. For advertising publishers, a progressive tax rate structure would apply:
- tax base up to HUF 500 million would be exempt,
- the portion between HUF 500 million and HUF 10 billion would be taxed at 2.5%,
- the portion between HUF 10 billion and HUF 40 billion at 4.5%,
- the portion exceeding HUF 40 billion at 7.5%.
For advertisers, the tax rate would be 2.5%.
The advertising-tax base derived from advertising activities of related parties would have to be aggregated.
Under the draft Hungarian autumn tax package 2026, a NAV-maintained register of compliant or non-taxable advertising publishers would also become available. Publishers included in the register would not be subject to a declaration obligation.
Failure to fulfil the registration requirement would be subject to significant penalties. However, NAV could not impose a penalty immediately and would first be required to issue a notice to remedy the deficiency.
Retail tax
One tax rate may triple
The retail tax would remain in force in 2027, and the tax bands would remain unchanged. At the same time, the proposal would increase the tax rate applicable to the portion of the tax base exceeding HUF 1 billion but not exceeding HUF 50 billion from 0.15% to 0.45%. All other tax rates would remain unchanged.
The amended rate would already have to be taken into account when calculating tax advances for tax years beginning in 2027.
The special tax rates applicable to the retail sale of motor fuels would remain unchanged in 2027.
Company car tax
New tax brackets may be introduced for high-performance vehicles
The rules on company car tax would primarily change from 1 January 2027 for passenger cars with an engine output exceeding 120 kW. Instead of the current single category, new tax brackets differentiated by engine power and environmental classification would be introduced.
For vehicles below 120 kW, the amendment would not result in any additional tax burden beyond the annual indexation.
A further tightening would limit the deduction of motor vehicle tax against company car tax to one passenger car selected by the taxpayer.
From 2027, plug-in hybrid vehicles would also become subject to company car tax.
Windfall tax on banks and special tax on financial institutions
Windfall tax may remain in place in 2027
The windfall tax applicable to credit institutions and financial enterprises would remain in force in 2027. The tax base would be the pre-tax profit for the 2025 tax year adjusted by specified correction items. The tax rate would be:
- 10% on the tax base up to HUF 20 billion,
- 30% on the portion exceeding HUF 20 billion.
The 2027 tax would have to be declared by 10 June 2027 and paid in two equal instalments, due on 10 June and 10 December. The tax incentive linked to increasing holdings of long-term Hungarian government bonds would remain available, up to 30% of the payable special tax. At the same time, the proposal would abolish the tax reduction related to support for spectator team sports.
Insurance tax and supplementary insurance tax
Tiered insurance tax system may be abolished
According to the draft Hungarian autumn tax package 2026, both insurance tax and supplementary insurance tax would remain in force in 2027. However, the current tiered insurance tax system would cease to apply below HUF 20 billion, meaning that the statutory tax rates for the respective insurance sectors would apply to the entire tax base.
The supplementary insurance tax would remain progressive. Insurers could continue to reduce their 2027 supplementary tax liability by increasing their holdings of specified long-term Hungarian government bonds. The tax benefit could amount to 60% of the nominal increase in the government bond portfolio, subject to the limitations set out in the law.
Financial transaction duty
Higher exemption threshold and higher maximum duty
The proposed amendments contain both favourable and burden-increasing elements. The exemption threshold for transfers initiated from private individuals’ payment accounts would increase from HUF 50,000 to HUF 150,000 per transaction. The exemption would continue not to apply to transfers initiated from sole proprietors’ business accounts.
For postal cash deposits, only the amount exceeding HUF 150,000 would form part of the duty base. The general duty rate would remain unchanged at 0.45%, while the maximum duty per transaction would increase from HUF 20,000 to HUF 30,000. The new rules would first apply to transactions executed after 31 December 2026.
New low tax scheme
Broader invoicing opportunities, stricter limitations
The planned reform of the low tax scheme (or itemised tax regime, in Hungarian: KATA) would once again allow sole proprietors subject to the regime to issue invoices to companies and other organisations.
We analysed the changes and their practical implications in detail in our article New low tax scheme in Hungary.
The final proposal:
- clarifies the calculation and reporting of the 50% revenue threshold,
- tightens the rules applicable to income received from employers and their related parties,
- contains more detailed provisions on mid-year entry into the regime and the related social security and social contribution rules.
Tax procedure rules
The draft Hungarian autumn tax package 2026 would amend Hungarian tax procedure rules in several areas. The proposed changes primarily affect the requirement of proper exercise of rights, the rules of evidence applicable during tax authority audits, as well as risk analysis procedures and representation before the tax authority.
Tightening of anti-abuse rules
The legislative proposal would define in greater detail the circumstances under which a taxpayer’s conduct may be regarded as improper exercise of rights. Such cases may include:
- where the exclusive or principal purpose of a transaction is to obtain a tax advantage, and there are no genuine economic, business or other reasons supporting the transaction apart from that tax advantage;
- arrangements built from transactions lacking an independent business purpose;
- transactions implemented through the involvement of economically unjustified intermediary entities.
One of the most significant elements of the amendment concerns changes to the rules of evidence applied during tax audits. Where evidence uncovered by NAV indicates the likelihood of an improper exercise of rights, the taxpayer would bear the burden of proving that the transaction was supported by genuine economic, business or other reasons beyond obtaining a tax advantage, and that these reasons would have made the transaction reasonable and economically justified even in the absence of the tax benefit. In addition, the taxpayer would also be required to demonstrate that the chosen structure is consistent with the proper conduct expected between independent parties.
As a result of the proposed changes, the adequate documentation of the business rationale behind tax-efficient transactions may become particularly important, especially in relation to intra-group reorganisations and financing structures. These provisions would enter into force on the day following the promulgation of the law.
Restriction of access to documents created during risk analysis procedures
The proposal would restrict taxpayers’ rights of access to documents. Under the new rules, taxpayers would not be permitted to inspect documents created during NAV’s risk analysis procedures. According to the explanatory memorandum, risk analysis constitutes an internal preparatory activity of the tax authority and does not in itself result in direct legal consequences for taxpayers. The purpose of restricting access is to protect the risk analysis methods used by the tax authority and to ensure the effectiveness of tax audits. The amendment would enter into force on the day following the promulgation of the law.
Simplified representation rules
The Hungarian autumn tax package 2026 would also amend the rules governing representation before the tax authority. The new provisions would allow organisational representatives of legal entities to act before NAV without a separate power of attorney, provided that their authority to represent the entity is evidenced by appropriate documentation.
The authorisation would have to be submitted to the tax authority:
- electronically,
- indicating the method and scope of representation,
- together with a document providing full proof of the representative’s authority.
The right of representation would become effective vis-à-vis the tax authority upon receipt of the notification. The amendment would also permit the joint appearance of statutory representatives and organisational representatives, thereby reducing the administrative burden associated with proving representation rights.
Changes to tax audit deadlines
The range of cases in which the deadline for a tax audit may be extended would be broadened. Under the proposal, the head of NAV would be entitled to extend the audit deadline once where estimation methods are applied for determining the personal income tax base. The duration of such audits could be extended up to 365 days. This provision would enter into force on the day following the promulgation of the law and would apply only to audits initiated thereafter.
Please note that the provisions presented in this article are based on the current draft of the Hungarian autumn tax package 2026. The rules may still change during the parliamentary debate and legislative process, therefore they are not yet in force.
The Hungarian autumn tax package 2026 may bring significant changes for businesses across a wide range of areas, from corporate and international taxation to employer obligations, administrative requirements and compliance matters. The practical impact of the legislative amendments may vary from company to company, making it essential to identify business-specific implications and potential risks in a timely manner. Our tax advisers can support you in interpreting the changes, assessing their impact on your business and planning the necessary actions. Feel free to contact our experts if you would like to ensure that your company responds to the new Hungarian tax rules in a timely and compliant manner.
This article is for general information purposes only and should not be considered as advice.
