What does this mean for companies?

The essence of the regulation remains unchanged: the global minimum tax aims to ensure an effective tax rate of at least 15% for large corporate groups. To achieve this, the Hungarian system applies the Qualified Domestic Minimum Top-up Tax (QDMTT), ensuring that income generated in Hungary is subject to an appropriate level of taxation. Preparing the 24GLBADO return is not merely an administrative task; it is also a complex calculation and data management challenge.

Key deadline

As a general rule, the final top-up tax return ensuring the global minimum tax level must be submitted and paid within 15 months from the last day of the relevant tax year. However, since 2024 is considered a transitional year, the filing and reporting obligations for the 2024 tax year must be fulfilled within 18 months after the end of the tax year when dealing with Hungary.

• Deadline for taxpayers with standard financial year: 30 June 2026
• Submission method: Hungarian Online Form Completion Application (ONYA)
• Type of return: combined advance and final 24GLBADO return

Practical challenges

Based on experience, compliance affects several areas simultaneously. The most common tasks include:

• collecting and harmonising consolidated financial data,
• managing different accounting standards,
• determining the effective tax rate by jurisdiction,
• establishing new reporting and data collection processes.

As a result, the global minimum tax requires significant organisational preparation not only from a tax perspective, but also from financial and IT perspectives in Hungary.

Legal background

The Hungarian regulation is based on Act LXXXIV of 2023 on ensuring the global minimum tax level in Hungary. The law defines in detail the calculation of the top-up tax as well as the related filing and reporting obligations, in line with the OECD Pillar Two framework and the EU directive.

Why is it important to address this now?

Accurate preparation is crucial for companies. A late or incorrect 24GLBADO return may result in:

• tax risks,
• penalties,
• and reputational risks.

The availability of the 24GLBADO return clearly indicates that the global minimum tax system is already in the operational phase in Hungary. Companies must therefore not only interpret but actively apply the rules.

The introduction of the 24GLBADO return takes the Hungarian practice of global minimum taxation to a new level. In order to meet the 30 June 2026 deadline, it is advisable to start data collection and prepare internal processes now, with expert support if necessary. The tax consulting team of WTS Klient Hungary is at your disposal!

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DAC9: Simplified administration

Furthermore, thanks to the DAC9 Directive, which provides for unified European implementation, the administrative burden is significantly reduced: corporate groups only need to submit the GloBE Information Return (GIR) data report in a single member state, and the data is automatically shared with the tax authorities of the relevant countries. The Hungarian legal system has implemented this through the amendment of Act XXXVII of 2013 and Act XC of 2025, the latter of which also promulgated the multilateral agreement ensuring automatic data exchange with non-EU countries (such as the United Kingdom or Canada).

Two new Safe Harbours

In addition, the “Side-by-Side” package published by the OECD on January 5, 2026, brought a breakthrough in the transatlantic debate, officially recognizing the US tax system as equivalent with the global minimum tax rules. As a result, from January 1, 2026, two new Safe Harbours have entered into force. The SbS Safe Harbour exempts those corporate groups from top-up taxes (IIR, UTPR) whose parent company operates in a recognized – for example, American – jurisdiction, while the UPE Safe Harbour provides protection for parent companies with high tax rates against paying the UTPR. It is important to note, however, that these exemptions are not retroactive, which means they do not affect the Hungarian domestic top-up tax (QDMTT). A significant change is that, under the new rules, the eligibility period for the transitional CbCR Safe Harbour exemption is extended by one year, meaning it will also apply to financial years beginning up to December 31, 2027 – and ending by June 30, 2029 at the latest – with a minimum tax rate of 17% for the simplified effective tax rate test.

 At WTS Klient Hungary, our tax advisors are happy to assist you with all questions related to Pillar 2 compliance. As part of our comprehensive tax planning and advisory services, we not only explain the relevant rules in detail but also develop tailor-made, optimal solutions for your business. Feel free to contact us!

This article provides general information and does not constitute advice.

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In our article we have summarised the key 2026 tax amendments in Hungary, grouped by tax type.

Personal income tax and social security

PIT exemption for mothers

A new PIT exemption has been introduced for mothers with two or three children. The incentive applies to biological and adoptive mothers who are entitled to family allowance or were entitled to it for at least 12 years.

• Income covered: income included in the consolidated tax base (e.g. employment income). However, the exemption does not extend to income from rental activities or capital income.

• How to claim: by indicating it in the family allowance declaration and through continuous advance tax declaration.

• Social contribution relief: if the PIT base is insufficient, the benefit can also be claimed as a family contribution allowance.

For mothers with three children, the exemption applies to income earned after 30 September 2025. For mothers with two children, the eligibility will be phased in gradually between 2026 and 2029 based on age brackets.

Other tax base allowances

• With the introduction of a new tax base allowance, infant care benefit (csed), child care benefit (gyed) and adoption benefit will also become tax‑exempt.

• The allowance for mothers under 30 can be claimed without an upper limit.

• The amount of the family tax allowance increased in two steps: from 1 July 2025 and from 1 January 2026.

Additional PIT changes

• For crypto asset transactions, the time limit of the tax equalisation rule is removed, meaning losses older than two years can also be recognised.

• SZÉP card spending rules change: between 1 December 2025 and 30 April 2026 it can be used for cold food purchases, but from 2026 it can no longer be used for home renovation. Previously, SZÉP cards could be used for building materials, furniture or household goods – this will no longer be allowed.

• The 2026 tax amendments broaden the range of tax‑free benefits: family allowance, accommodation provided by the Hungarian branch of foreign companies, private use of electric bicycles, and bank compensation for phishing damages all become tax‑exempt.

• In the flat‑rate taxation, the 40% cost ratio increases in two steps.

Social security changes

• For sole proprietors and partnerships, the minimum contribution base is reduced from 112.5% to 100% of the minimum wage (or guaranteed minimum wage). For corporate members, this also affects the small business tax (KIVA) base.

• A new social security status is introduced: permanent contract work. As a result, social security and social contribution tax liability arises on the contractual fee, but at least 30% of the minimum wage.

• For foreign assignments, the national average gross wage increased to HUF 715,765 as the contribution base.

• The health service contribution rises to HUF 12,300 per month from 2026.

• Administrative changes: introduction of the Complex Employment Relationship Register and the e‑Social Security booklet.

• A new social contribution tax liability applies to payments made to pensioners drawing a direct pension claiming PIT allowances, if total income exceeds certain limits.

Digitalisation

As of 31 December 2026, the Hungarian Tax Authority (NAV) will phase out the General Form Completion Program (ÁNYK), initiating the mandatory transition to data‑driven platforms.

Alternatives to replace ÁNYK include:

• Online Form Completion Application (ONYA) and the e‑VAT web interface for private individuals, SMEs and taxpayers with few transactions;

• M2M solutions for taxpayers with complex structures and large transaction volumes.

As part of the 2026 Hungarian tax amendments, Identification Based Document Authentication (AVDH) will also be discontinued and replaced by User Assignment to Document Service (FEDOR).

Value added tax

Thresholds and rates

• The threshold for VAT exemption for small taxpayers will increase gradually: HUF 20 million from 2026, HUF 22 million from 2027, and HUF 24 million from 2028.

• The VAT rate on beef and related offal will drop from 27% to 5% from 2026.

• The reduced 5% VAT rate on new residential properties will remain available in 2026. Under the transitional rules, the reduced rate also applies to advances received and supplies completed after 31 December 2026 if the building permit becomes final by the end of 2026 or construction has been notified by then.

Reporting and invoicing rules

• The domestic summary report must include the amount of VAT actually deductible at invoice level. E‑VAT users are exempt from this obligation.

• As part of the 2026 tax amendments, new data fields are added to the online invoice data reporting: in case of legal succession or VAT groups, the tax numbers of the predecessor and group members must also be reported.

• E‑invoicing became mandatory for electricity, natural gas and water utility providers. In these cases, e‑archiving rules require particular attention – including on the invoice recipient’s side.

Other VAT changes

• VAT groups: the establishment of VAT groups is simplified, with automatic representative appointment if the previous representative ceases.

• The transition to e‑cash registers must be completed by 1 July 2028; until then, online cash registers remain allowed. From 1 September 2026, receipt data reporting becomes mandatory: manually issued receipts must be reported within three days on a daily basis, while e‑receipts require real‑time reporting since 1 July 2025.

• Reverse charge rules will apply to domestic natural gas transactions between Hungarian VAT‑registered traders.

• From 1 October 2025, customs representatives must issue a declaration on the assigned right to deduct VAT in VAT returns.

• Travel service providers no longer need to indicate the tax base and transferred tax on invoices (except for online reporting).

Corporate income tax, KIVA and global minimum tax

Corporate income tax

• R&D tax base allowance for R&D activities carried out jointly with higher education institutions, the Hungarian Academy of Sciences or other research institutions increases from HUF 50 million to HUF 150 million.

• The upper limit for the R&D tax allowance in such cases becomes 25/50/100% of costs depending on development type, up to HUF 500 million per year. The time limit also changes: the selected tax credit option can be modified after five years instead of six.

• New environmental investment tax incentives and new development tax incentives for clean technologies are introduced.

• The threshold for determining monthly or quarterly CIT advance payment frequency increases from HUF 5 million to HUF 20 million.

• The 2026 tax amendments clarify rules on preferential asset transfers: partial fulfilment of shareholding requirements results in partial tax liability, and civil law demergers now also qualify as preferential asset transfers.

• Rules for reported shares become applicable to cross‑border transformations.

• For micro‑businesses, the balance sheet total threshold increases from HUF 150 million to HUF 180 million, and the annual net revenue threshold rises from HUF 300 million to HUF 360 million.

• The employment tax base allowance for micro‑enterprises increases.

Public CbCR

Multinational groups with consolidated revenue above EUR 750 million are obliged to prepare public country‑by‑country reports. The first publication relates to the 2025 financial year and is due in 2026.

Small business tax (KIVA)

KIVA changes mainly involve doubling the entry and exit thresholds (headcount and revenue), significantly expanding eligibility. Electronic money assets are removed from the definition of cash, meaning their changes no longer affect the KIVA base.

Global minimum tax (GloBE)

• The GloBE registration deadline has been extended to 28 February 2026.

• Default penalty for non‑compliance with GIR reporting can reach HUF 10 million.

• 2026 tax amendments refine transitional and permanent safe harbour rules; further details are expected.

Transfer pricing changes

The new regulation of the Hungarian Ministry for National Economy aims for closer alignment with the OECD Guidelines. It applies from 2026, but some rules for local files may apply to 2025.

• Master file: no master file required if total net value of controlled transactions subject to local file requirements does not exceed HUF 500 million. This exemption applies from 2026.

• Local file: threshold increases to HUF 150 million.

• Documentation requirements become stricter for cost recharges and free transfers of funds.

• Documentation content is modified to align with data reporting requirements.

• Benefit test: taxpayers must demonstrate that the service is fully necessary for their business and that they would be willing to pay an unrelated party under similar terms.

• Voluntary year‑end transfer pricing adjustments: any value within the arm’s length range may be selected; median adjustments are no longer mandatory.

The new decree contains further detailed rules on intangibles, industry analysis, method and margin selection, database research, simplified documentation and low value‑adding services.

Tax procedure

The 2026 tax amendments include several procedural changes to increase audit efficiency, enhance digital processes and strengthen enforcement.

• Audit deadlines for chain transactions are extended (up to 365 days for reliable taxpayers).

• Fees increase for advance tax rulings and APA procedures.

• From 2026, instead of self‑revision, claims based on unconstitutionality, EU law breaches or municipal law violations must be submitted through a separate request.

• Automatic decision‑making is introduced for certain case types.

• VAT and social contribution filing delays exceeding 90 days will result in automatic tax number deletion; stricter penalties apply for e‑cash register non‑compliance.

• Removal from negative lists (e.g. list of employers with unreported employees) may be requested once a year under certain conditions, with payment of a penalty.

• Automatic payment relief will be available for higher thresholds for reliable taxpayers and for both individuals and legal entities.

Other tax changes

• For retail tax, exemption thresholds and tax brackets increase. These apply retroactively to 2025, allowing refund claims on advances and tax differences. Online platforms are also subject to retail tax from 2025.

• Rules for certain special taxes change: financial institutions face higher tax rates; energy suppliers’ profit tax rate decreases to 31% from 2026, with new investment incentives available.

• The advertising tax returns from 1 July 2026.

• EPR fees increased significantly in 2025.

• CBAM payment obligations become effective in 2026; affected taxpayers must register immediately.

• Loans forgiven by owners in liquidation become exempt from duties if the procedure ends with company court deletion. Suspended duty on plots for residential construction can be cancelled more easily upon proof of occupancy.

• Renewable energy investments: land for solar or wind power plants may receive partial exemption from transfer duty.

• Rules on replacement purchases are amended favourably.

• Excise tax indexation date moves to 1 July.

• Inflation‑indexed increases apply to vehicle tax, company car tax and vehicle transfer duty.

The 2026 tax amendments in Hungary are highly complex and introduce numerous new administrative and compliance obligations for taxpayers. To fully understand and comply with the rules outlined above, we recommend seeking professional assistance. The tax consulting team of WTS Klient Hungary is at your disposal.

This article provides general information and does not constitute advice.

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• to reduce administrative burden,
• to clarify legal conditions, and
• to implement guidelines of international legal sources

in several tax types. In this article, we summarise the most important changes.

Value added tax

VAT groups

• Creation of VAT groups: The Hungarian 2025 autumn tax package would simplify the process of creating VAT groups. In the future, a statement by the member that its registration system is capable of clearly separating internal and external transactions would be sufficient, so it would no longer be necessary to demonstrate this.

• VAT group representative: In case of termination of a VAT group representative, if the group does not appoint and register a new representative within 15 days, the Hungarian tax authority would automatically appoint the member with the highest tax performance to this role. The group representative would cease to be such if the member in question were to be subject to liquidation or involuntary deregistration proceeding.

Data reporting obligation

Based on the proposal, it will be mandatory to indicate the actual amount of VAT to be deducted at the invoice level in the VAT return summary report, not just the tax base and the VAT transferred. This provision would apply to the main pages, the pages containing amendment and cancellation invoices, and the data reporting relating to advance invoices. The amendment would enter into force in July 2026.

VAT rate change

From 1 January 2026, the VAT rate payable on the sale of beef and related offal would be reduced from the current 27% to 5%.

Global minimum tax

• New definitions: In connection with the application of the transitional CbCR safe harbour rules, the definitions of simplified covered tax, recognised CbCR, qualified financial statements, and simplified effective tax rate would be introduced.

• Clarification of transitional tax rates: With regard to the transitional relief for substance based income exclusion, it would be clarified which transitional tax rate would have to be paid in which year.

Personal income tax

Mothers raising two or more children

The Hungarian 2025 autumn tax package would also simplify the tax advance declaration process in connection with the tax allowance for mothers raising two or more children.

• No separate declaration required: From 1 January 2026, mothers of three children could indicate on their family allowance declaration form if they wish to claim the allowance for mothers raising three children. Mothers of two children who gradually become eligible will also be able to take advantage of this option.

• Continuity: The mother concerned may also declare to her employer that her declaration should be considered a continuous tax advance declaration. This declaration would be valid until a new declaration is submitted.

• Tax exemption for mothers raising or having raised two children: This will be introduced gradually over four years, until 2029, depending on age.

Crypto transactions

In the case of crypto transactions, the time limit for tax equalisation would be eliminated. This means that not only losses from the previous two years, but also earlier losses not yet included in tax adjustments could be offset against trading profits in the current year. For the purposes of tax adjustment, records must be kept that clearly show the amount of losses not yet utilised in tax adjustments. This option would already be available in the 2025 personal income tax return, but it is a condition that losses older than two years must have been reported in previous years’ returns.

Compensation from credit institutions in the event of data theft

In the case of bank customers who have fallen victim to data theft, the amount reimbursed by the bank out of fairness would be considered tax-free income. The tax exemption applies to compensation not exceeding the amount of the loss; for amounts exceeding this, the general rules apply. This rule would take effect on the day following the adoption of the bill.

Social security and social contribution tax

From 1 January 2026, permanent contract work would be introduced. In this relationship, social security contributions and social contribution tax would have to be paid on the contractual fee, but at least 30% of the minimum wage. The principal may declare the permanent nature of the contract work, thereby ensuring the continuity of the insurance relationship until the end of the legal relationship and reducing subsequent administration.

Social security registration system

According to the Hungarian 2025 autumn tax package, the development of a complex IT system would help individuals access data related to health insurance benefits and pension contributions on a single platform, thereby facilitating administrative processes.

Accounting

The bill clarifies related parties‘ transactions with each other where they have agreed on the subsequent settlement of differences arising from market prices. The clarification would allow taxpayers to apply a market price determined within the market price range agreed upon by the parties, even if it differs from the median, in their accounting records, as opposed to the median tax base adjustment in the case of subsequent accounting price adjustments. According to the Hungarian 2025 autumn tax package, the amendment will apply to the 2026 financial year, but it will also be possible to opt for its application for 2025.

Corporate tax

Support for spectator team sports

The Hungarian 2025 autumn tax package clarifies the conditions for the disposal of tangible assets acquired from the support of spectator team sports, especially in the case of free transfer.

Tax relief for R&D activities

• Upper limit of tax allowances: According to the proposal, the legislator would set the maximum tax allowance for R&D projects carried out jointly with research institutes, higher education institutions, and the Hungarian Academy of Sciences at 10% of R&D costs, with an annual upper limit of HUF 500 million. The proposal is expected to enter into force on the day following its promulgation.

• Time limit: The time limit for choosing the R&D tax allowance will also change: taxpayers will now be able to change the method of claiming the tax allowance from the fifth year following the first tax year chosen, instead of the previous sixth year.

Small business tax

The Hungarian 2025 autumn tax package would remove electronic funds from the concept of cash from 1 January 2026, so they would not have to be taken into account when determining tax base adjustment items.

Duties

• Forgiving loan: Forgiving shareholder’s loan would become duty-free. An exception to this would be if the liquidation does not end with the deletion of the company from the company register. In the latter case, the duty amount must be paid with a late payment surcharge.

• Property rights related to home ownership: The duty assessment provisions relating to the acquisition of home ownership by private individuals would be extended to the acquisition of property rights related to home ownership.

• Leaseholder rights: From 1 January 2025, not only the fact of financial leasing can be indicated in the real estate register, but also the leaseholder’s right to transfer ownership. This option is currently provided for in the Hungarian Land Registry Act, but the Hungarian 2025 autumn tax package would transpose this change into the Hungarian law on duties as well.

Local taxes

• Lessee’s right: In addition to the duty law, from 1 January 2026, the law on local taxes would also include the lessee’s right and the right related to the retention of ownership in the definition of property rights.

• Municipal tax: Under the Hungarian 2025 autumn tax package, local governments would not be able to levy municipal tax on forests and related property rights.

Tax administration

The Hungarian 2025 autumn tax package would introduce automatic decision-making in tax matters, allowing the Hungarian tax authority to make decisions automatically if all the necessary data is available.

In this article, we have tried to provide a thorough summary of the most important parts of the draft Hungarian autumn 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.

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The global minimum tax (Pillar 2) has been one of the most pressing topics for tax and financial professionals, as well as executives of multinational corporations, across the European Union for several years now. This is largely due to the ongoing evolution of regulations related to this tax regime. As a result of changes in EU legislation, several amendments and clarifications have recently been proposed in Hungary as well. The latest developments concern global data exchange and the application of transitional CbCR safe harbour rules under the Pillar 2 framework.

The next step in centralised data reporting: global data exchange

One of the key elements of the latest Hungarian legislative proposal related to Pillar 2 is the introduction of centralised data reporting for Hungarian constituent entities, significantly reducing their administrative burden. The first step in centralised data reporting was the DAC9 Directive, adopted by the European Union in spring. Hungary is in the process of implementing this directive, likely as part of the upcoming autumn tax package.

The new proposal of the Hungarian government prepares the groundwork for data exchange with non-EU jurisdictions. In practice, this means that if a GloBE Information Return (GIR) is filed in a country that has signed a GIR MCAA (Multilateral Competent Authority Agreement) with Hungary, then there will be no need to file the same return again in Hungary. Annex 1 of the draft legislation lists the relevant jurisdictions, including Canada, Japan, the United Kingdom, and Australia, with which Hungary plans to establish such data exchange agreements.

Technical clarifications in the 2025 autumn tax package

In addition to the anticipated implementation of the DAC9 Directive, the 2025 autumn tax package in Hungary will also include several technical and interpretative clarifications concerning the transitional CbCR safe harbour rules set out in the Hungarian 2023 Act LXXXIV on the Global Minimum Tax (Act on GMT).

The two most significant technical clarifications under the Pillar 2 legislation are as follows:

• Refinement of the definition of simplified covered taxes: Taxes that are not reported as income taxes in financial statements will not be eligible as simplified covered taxes. In the Hungarian context, this may affect the local business tax, which – depending on the accounting standards applied – is not classified as an income tax (e.g., under Hungarian accounting rules). While this clarification could already be inferred from the OECD’s background materials, it will now be explicitly incorporated into Hungarian legislation.

• Establishing fixed percentages for substance-based income exclusion: These percentages will support uniform legal interpretation among Hungarian taxpayers and reduce uncertainty in the application of the Pillar 2 rules.

Filing the Qualified Domestic Minimum Top-up Tax (QDMTT) advance return

Hungarian constituent entities subject to the global minimum tax must submit their QDMTT advance return for the 2024 tax year by 20 November 2025. If an advance payment obligation arises, the tax liability must also be paid at the time of filing. It is essential to keep this deadline in mind, as failure to submit the return may result in a penalty of up to HUF 10 million.

UPDATE! Draft QDMTT advance tax return released

To support taxpayers’ preparation, the Hungarian tax authority has published the draft version of the advance tax return for the Qualified Domestic Minimum Top-up Tax (QDMTT), the 24GLBADO form. Apart from the draft tax return form, the filling instruction and a supporting document in XML format to assist in electronic submission have also been released. The return will be filed through the ONYA online platform (Hungarian online document management webpage), and – as expected – must be submitted even if the taxpayer has no advance payment obligation.

Taxpayers will have limited time to interpret and complete the QDMTT advance return. At WTS Klient Hungary, our tax advisors are happy to assist you with this return or any other questions related to Pillar 2 compliance. As part of our comprehensive tax planning and advisory services, we not only explain the relevant rules in detail but also develop tailor-made, optimal solutions for your business. Feel free to contact us!

This article provides general information and does not constitute advice.

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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

• Binding 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.

A Hungarian summer tax package 2025 adopted bejegyzés először WTS Klient Hungary | tax | accounting | payroll | advisory | HR services | digital solutions | state aid-én jelent meg.

What is the simplification about?

One important innovation of DAC9 is that it allows for the centralised filing of a global minimum tax return. This means that the parent company or a designated group member can submit the new return, updated in January, on behalf of the group for all members of the group, instead of each of them having to do it separately in their own country. A standardised Top-up Tax Information Return (TTIR) will be introduced within the EU and Member States will automatically share data relating to the global minimum tax.

A possible consequence of the change is that group members will be less involved in the return process at national level, but intra-group data reporting should still be encouraged.

What are the key deadlines?

The Directive provisions adopted at EU level must be transposed into national law by Member States by 31 December 2025. The change will also affect the financial year 2024, for which the reporting obligation will have to be fulfilled by 30 June 2026 at the latest. The deadline for transmitting the data to the relevant tax authorities is 31 December 2026, but for subsequent years the deadline will be three months from the date of receipt of the return.

Which group member should submit the global minimum tax return?

Consideration should be given as to which group member jurisdiction is the most appropriate to submit the global minimum tax return, i.e. which group member should be designated for this task. A possible consideration in this decision is whether a particular group member is covered by a temporary exemption (e.g. CbCR exemption, etc.) or, in the absence of such an exemption, whether the data required for GloBE compliance is already being collected.

Since the exchange of data will only be automatic within the European Union, if the group has a non-EU (third country) group member, it is also necessary to check whether the country concerned has acceded to the OECD (Organisation for Economic Co-operation and Development) Multilateral Competent Authority Agreement on the Exchange of GloBEInformation (GIR MCAA). If it has not acceded, it may still be obliged to submit a local global minimum tax return.

A transitional simplified jurisdictional reporting framework (Simplified Framework) will also be available as a transitional option, which could reduce the administrative burden for businesses.

What else should businesses look out for?

It is recommended to review reporting requirements in a timely manner to ensure that the systems used by the company are able to accurately capture and report the required information to ensure that the return obligation is properly fulfilled.

It is important to keep abreast of any changes in the regulatory background to the OECD’s Global Minimum Tax Information Return (GIR) and the EU’s Form TTIR.

It is also important to be aware of and comply with the rules because the 2025 tax inspection plan of the Hungarian tax authority concerning GloBE includes a priority review of the so-called covered taxes (corporate tax, innovation contribution, etc.).

Given that the top-up tax liability is already required to be included in the 2024 financial statement, the Hungarian companies concerned will have to perform the global minimum tax calculation shortly. The tax advisors at WTS Klient Hungary will be happy to assist you with the calculation and any other questions related to the global minimum tax return. As part of our tax planning and consulting services, we not only explain the details of the rules, but also develop the most optimal solutions tailored to your company. Contact us with confidence!

This article provides general information and does not constitute advice.

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Global minimum tax changes due to the US

On 20 January 2025, the day of his inauguration, Donald Trump, the new US President, announced that the Global Tax Deal –  of which the Global Minimum Tax Agreement is a part – will no longer apply in the US.

The previous US presidency attended the G7 and G20 summits in support of the Global Minimum Tax, and eventually negotiated an agreement with nearly 140 countries to adopt the OECD’s minimum tax proposal. However, the local implementation of the new regime has so far been achieved in a small number of countries. Despite President Biden’s support for the introduction of a global minimum tax, he failed to secure sufficient congressional support to implement the minimum tax in the US.

President Trump has now made clear in his executive order that the US is withdrawing its support for the Global Minimum Tax agreement, which would have allowed countries that had introduced a minimum tax to impose an additional tax on US multinationals.

America’s withdrawal from the global minimum tax system raises a number of issues, including the taxation of US multinationals abroad. The Trump administration plans to impose punitive taxes if a country tries to tax a US company under the UTPR (Undertaxed Payments Rule). On the other hand, it is questionable how other major economies that have not implemented the minimum tax rules (e.g. India, China) will react to this decision.

Hungary on the transitional qualifying list

Among the global minimum tax changes at the beginning of the year, the next recent news is that on 15 January, the OECD released the list of jurisdictions with transitional qualified status for the purposes of the Income Inclusion Rule (IIR) and the Qualified Domestic Minimum Top-up Tax Rules and QDMTT Safe Harbours.

In its qualification, the OECD assesses whether the legislation of each jurisdiction is in line with the common international set of rules for the global minimum tax. The Hungarian Minimum Tax Act has been granted qualified status on a temporary basis for the collection of QDMTT and IIR type additional taxes. In practice, this means that the domestic minimum top-up tax introduced in Hungary will be qualified for the year 2024.

This is also important because if the domestic minimum top-up tax regime in Hungary were not to be classified as qualified, the calculation based on the IIR mechanism in the country of the parent company may result in an additional top-up tax liability for the Hungarian group members. On the other hand, it is also an administrative relief for the parent company, as they do not need to make additional top-up tax calculations for the Hungarian group members.

The next step for the countries introducing the minimum tax would be to perform peer review about each other’s domestic top-up tax systems.

 Global minimum tax changes affecting the reporting

The third new feature of the global minimum tax changes is the updated minimum tax return, the so-called GIR (GloBE Information Return), which was also published on 15 January. The new GIR contains useful information for both taxpayers and tax administrations. To further assist tax administrations, the OECD has also published an XML schema based on the new GIR, which countries are expected to use for mutual data exchange. The first deadline for taxpayers concerned to file their returns will be 30 June 2026.

A draft Multilateral Competent Authority Agreement (MCAA) has also been published in connection with the GIR return. This agreement aims to facilitate the central registration of GIR and the exchange of data between countries by regulating at global level the conditions and functioning of the automatic exchange of GIR information. In practice, this is a significant additional administrative relief for taxpayers, since if the ultimate parent company or designated filing entity files a GIR return in a country that has acceded to the MCAA, it is no longer necessary to file a GIR return in Hungary. The next expected step in the global minimum tax changes will be the adoption of the DAC9 Directive, which is currently being worked on at EU level. The DAC9 Directive has similar objectives as the MCAA, but only concerns EU Member States.

The administrative guidelines have also been extended

As part of the January “global minimum tax publication package”, the OECD published new administrative guidance on the application of the transitional rules in Article 9.1 of the Model Rules. The guidelines provide further clarification on the treatment of deferred tax assets created in the transition year.

Given that the top-up tax liability is already required to be included in the 2024 financial statement, the Hungarian companies concerned will have to perform the global minimum tax calculation shortly. The tax advisors at WTS Klient Hungary will be happy to assist you with the calculation and any other questions related to the global minimum tax changes. As part of our tax planning and consulting services, we not only explain the details of the rules, but also develop the most optimal solutions tailored to your company. Contact us with confidence!

This article provides general information and does not constitute advice.

A Global minimum tax changes 2025 bejegyzés először WTS Klient Hungary | tax | accounting | payroll | advisory | HR services | digital solutions | state aid-én jelent meg.

As we wrote in our previous article, the provisions of the 1979 Hungarian-U.S. tax treaty, which was valid until 2024, no longer applies since 1 January 2024, given that the official communication stated that the  U.S. side found the treaty unfavourable. At the same time, the new Hungarian-U.S. tax treaty, which was negotiated in the 2000s and passed by the Hungarian Parliament, has not entered into force either, since the U.S. Senate has not approved it.

Causes and consequences

One of the main reasons given by the U.S. Department of the Treasury for the termination of the tax treaty in July 2022 was that the Hungarian government had communicated that the global minimum tax is not intended to be introduced in Hungary at that time. Although the Hungarian position has changed in the meantime and in October 2023 the Hungarian Ministry of Finance published a draft law on the introduction of the global minimum tax transposing EU Directive 2022/2523 into Hungarian law, the Hungarian-U.S. tax treaty has been terminated. In the light of the change in legislation, it was necessary to re-evaluate all international transactions and to examine their tax consequences, taking into account, for example, that both states are entitled to tax income from the other state under their respective national laws and that this type of income is classified as non-treaty income in Hungary.

Why is a new Hungarian-U.S. tax treaty important?

Based on the resolution that has been promulgated, a new Hungarian-U.S. tax treaty is finally expected to be drafted in the near future, which will once again resolve situations where double taxation may arise for an individual or a company. The treaty could determine in such situations which state may have the right to tax and to what extent, and in what form the avoidance of double taxation (exemption, credit method) should be ensured.

Although the establishment of the new tax treaty is still in its early stages, companies with any U.S. interest should be prepared for the changes that will occur with the establishment of the treaty.

Our experts have significant experience in both corporate and individual double taxation issues, as well as in the taxation of capital income from the United States, and are ready to help clients explore how the new Hungarian-U.S. tax treaty may affect them. Contact us!

This article provides general information and does not constitute advice.

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Uncertain and unprepared companies

 The Minimum Tax Act came into force in Hungary in 2024, under which multinational groups with revenues of more than 750 million EUR will be subject to a global minimum tax. However, the great interest in the conference undoubtedly confirms, and a non-representative online survey by WTS Klient Hungary also revealed, that a significant proportion of business leaders, almost one third, are not even sure whether their company will be subject to the new tax. The survey also found about the same proportion of professionals who feel completely unprepared and those who were unaware that the companies concerned will have to report by the end of the year. 70% of respondents believe that the Pillar Two rules are more complex than average, and 22% of them also believe that they are extremely complex, revealed András Szadai, tax partner of WTS Klient Hungary and host of the event, at the beginning of the Global Minimum Tax Conference.

Reassuring developments

Although the deadline of 31 December is fast approaching, the required data reporting form has only recently appeared on the website of the Hungarian tax authority, and the default penalty can reach up to HUF 5 million, there are some reassuring developments.

For example, various exemptions can be claimed under the temporary CbCR Safe Harbour or the permanent Safe Harbour rules and, as Lars Behrendt, tax expert and partner at WTS Germany explained in his presentation, there are already cluster methods developed for what to do in case of involvement of countries (e.g. China, India or the US) where implementation has not yet been announced or where it is not yet foreseen in the near future. It is clear that if these economically important countries do not introduce the Pillar Two rules, it will be more difficult to apply the Hungarian rules or collect tax that Hungary may be liable for.

During the roundtable of the Global Minimum Tax Conference it was also mentioned that it is worth submitting the data reporting sheet even if the data is incorrect, as there will be a possibility to amend the data report. For the domestic declarations to be completed by the end of the year, domestic group members can decide to have a Hungarian group member designated by them complete the declaration of all Hungarian group members in one form. In addition, under the DAC9 proposal published by the European Commission in October, it is likely that it will be possible for the Globe Information Return (GIR) to be completed by the parent company or a designated group member and received through information exchange by the EU Member States concerned in 2026.

Pillar Two in Hungary: detailed rules still to come

Although the ministerial decree containing important detailed rules, which is also mentioned in the Global Minimum Tax Act, has not yet been published, dr. Szilvia Tormáné Boris, corporate tax expert at the Hungarian Ministry of Finance, tried to reassure the participants: despite the fact that the detailed rules concerned have not yet been introduced in detail into the Hungarian legal environment, the OECD model rules at international level apply in accordance with the principles of the law.

The international development of the Pillar Two rules is ongoing: the latest international negotiations aim at identifying tax avoidance structures and transactions related to the global minimum tax and at enabling mutual exchange of data on the global minimum tax (GIR) reporting between Member States at EU and global level (DAC9 Directive proposal and OECD Multilateral Competent Authority Agreement), said the expert.

Tax advisors at WTS Klient Hungary keep abreast of domestic and international Pillar Two regulations and will be happy to help you navigate the topic. As part of our tax planning and consulting services, we not only explain the details of the rules, but also develop the most optimal solutions tailored to your company. Contact us with confidence!

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