The most widely discussed element of the 2026 Hungarian tax package is expected to be the tightening of the rules governing trusts, but substantial changes are also anticipated in the areas of the retail tax, corporate tax incentives, and environmental taxes.

Trusts: a new era begins

The 2026 Hungarian tax package will significantly reshape the taxation of trust structures and private foundations in Hungary. The purpose of the reform is to eliminate advantages that, in certain cases, provided significant tax-saving opportunities.

Asset transfers under the previous and fresh rules

Formerly, assets transferred into trust structures could be revalued to fair market value on a tax-neutral basis. Therefore, the former rules did not impose taxation at the entry stage (upon the transfer of assets into the structure). Subject to certain conditions, the revalued assets could be distributed to beneficiaries tax-free after five years.

According to the new, accepted 2026 Hungarian tax package, in the future the following must be determined upon the transfer of assets:

• the original acquisition value of the asset, and

• the unrealised increase in asset value resulting from the revaluation.

Upon the distribution of assets, if the original asset transferred into the structure – for example, a shareholding transferred into the structure for the benefit of the settlor’s children – is distributed, no taxable event arises. In such a case, the beneficiary’s acquisition value for any future disposal will be the acquisition value existing prior to the transfer into the trust structure.

Special rules

The situation is different if the aforementioned shareholding is sold from the trust property and the gain is thereby realised. In such a case, where the proceeds are distributed to the beneficiary, the distribution remains tax-free only up to the amount of the original acquisition value, while the excess amount is generally taxed as a dividend.

The 2026 Hungarian tax package also introduces specific rules for situations where the beneficiary acquires an asset following the death of the settlor. In such cases, the beneficiary’s acquisition value is aligned with the revalued amount, which may result in significant tax advantages.

Special rules will also apply to:

• the transfer of crypto-assets into trust structures,
• the free-of-charge use of assets in the trust property.

The original purpose remains, tax advantages are reduced

The amendment may be particularly important for private individuals and entrepreneurial families that use trust or private foundation structures as part of their wealth planning strategy in Hungary. At the same time, it is important to note that the original functions of these structures – preserving family wealth, facilitating generational succession, and providing general asset protection – will remain intact.

Mandatory tax authority audits are coming

The 2026 Hungarian tax package not only reshapes tax rules but also strengthens tax authority oversight over trust structures.

As part of this process, the Hungarian tax authority will conduct mandatory audits:

• first, in relation to trust structures and private foundations established before 12 September 2023,
• then, from 2028 onwards, in relation to all such structures within the applicable statute of limitations period.

Affected taxpayers may therefore wish to review, before any official investigation:

• their established structures,
• the related agreements,
• the relevant documentation.

Retail tax: a step in the right direction, but not a complete solution

As part of Hungary’s RRF commitments, the 2026 Hungarian tax package abolishes the tax base aggregation rule applicable to the retail tax. This is clearly a positive development, as the provision has long been at the centre of disputes under EU law.

In our view, however, it remains questionable whether this amendment alone resolves the issues relating to previous periods. The following concerns remain:

• It cannot be ruled out that the rules applied between 2020 and 2025 may continue to raise concerns under EU law. As a result, in certain cases, claims may still be pursued through special tax refund procedures.
• Furthermore, the amendment does not affect the rule applicable from 2025 that creates particularly unfavourable consequences for certain foreign e-commerce operators. These businesses must still determine the applicable retail tax rates based on their global turnover and may only subsequently apply the exemption relating to foreign revenue.
• The structure may therefore continue to result in discrimination against foreign online retailers, whose tax burden may have increased significantly from 2025. In our opinion, businesses within this sector should also consider the possibility of pursuing a special tax refund procedure.

The step towards compliance with EU requirements is therefore welcome; however, in our view, further amendments would be necessary to achieve a comprehensive resolution.

We will discuss this topic in more detail in a separate article soon.

Corporate tax incentives: narrowing opportunities

The 2026 Hungarian tax package also affects the corporate sector, as it contains gradual phase-out of several corporate tax incentives. Under the changes:

• certain historic building tax incentives will be phased out,
• the growth tax credit regime will be abolished,
• the tax advantages associated with public-interest asset management foundations performing public functions will be gradually reduced.

Based on the previously announced tax programme, further significant changes can be expected in the near future, and we will, of course, continue to report on these developments.

Doubling air pollution charges and the abolition of the carbon allowance tax

In the area of environmental taxation, the most significant amendment included in the 2026 Hungarian tax package is a substantial increase in air pollution charges. The applicable charges will double for emissions of:

• sulphur dioxide,
• nitrogen oxides,
• non-toxic particulate matter.

According to the legislator, the increase is intended to reinforce the “polluter pays” principle.

Industrial and manufacturing companies may therefore wish to review in advance:

• their emissions data, and
• the expected additional costs.

CO₂ allowance tax: refund opportunity will become available

One of the more notable elements of the 2026 Hungarian tax package is the retroactive abolition of the carbon allowance tax, together with the possibility of reclaiming tax previously paid, as well as the related interest.

Affected businesses may submit their applications to the Hungarian tax authority within 90 days following the entry into force of the legislation.

The 2026 Hungarian tax package has been adopted and the majority of its provisions will enter into force on 31 August 2026. According to the new rules, significant changes are coming in the areas of trust and several other fields of taxation. Businesses and private individuals should review their structures and tax risks as soon as possible in order to avoid unpleasant surprises when the rules enter into force and to ensure that they do not miss potential opportunities. The tax experts of WTS Klient Hungary are ready to assist you in your preparations and in planning the necessary steps.

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Amendment to Act on Investment Companies and Investment Funds

The most important changes to the Czech Act on Investment Companies and Investment Funds made by an amendment in 2021 are compared to the previous year the following:

• Investment fund with legal personality: The Act was broadened by a new provision concerning an investment fund’s board of directors, whereby the investment fund’s board of directors with legal personality may be only one member, and its member can only be a legal entity, provided that the investment fund with legal personality is not a self-governing investment fund.

• Joint stock company with variable share capital: The statutory director of a joint-stock company with variable share capital, which is an investment fund, no longer has full management and therefore does not determine the basic focus of business management. The general meeting of a joint-stock company with variable share capital now does not elect or dismiss the statutory director nor approve his/her contracts or changes to that contract. Furthermore, the provision authorizing the legal entity to become a statutory director was removed if the conditions for membership of the Board of Directors are met. In the event that the same person wishes to fill more than one senior position in the same fund or company, a new consent from the Czech National Bank to perform another senior position is not required if the Czech National Bank has already granted one permit.

Reduction of support for solar power plants

Other significant changes in 2021 in the Czech tax system that may be important for foreign investors are the changes to green tax green tax in the Czech Republic. Thanks to the photovoltaic boom of 2009 and 2010, purchase prices of electricity produced by solar plants have increased several times over a period of time. For this reason, the government of the Czech Republic has decided to reduce support for solar power plants to a minimum level within the range set by the European Commission. The yield percentage is thus to be reduced from 8.4% to 6.3%. The main reason was the disparity between the support of solar power plants and their share in electricity generation, as they account for only 2% of the total electricity production in the Czech Republic.

Electricity tax

Taxpayers in the Czech Republic are obliged to pay a tax on electricity from renewable sources from 1 January 2016, when the law that abolished the exemption of environmentally friendly electricity from the electricity tax came into force. The obligation to pay an electricity tax applies to production plants with an installed capacity of over 30 kWp whose production meets their consumption. Technological consumption is not subject to the tax.

A tax return must be filed monthly. It is necessary to register for the tax at the locally responsible customs office in the Czech Republic, based on the address of the manufacturer’s registered office. However, if the manufacturer is not a taxpayer by law, he/she is not obliged to register. In case the manufacturer is registered, he/she must file a zero tax return on a monthly basis.

Subsidies

New projects are no longer eligible for operational subsidies in the Czech Republic but are entitled to other forms of assistance. Above all, they can apply for an investment grant under the New Green Savings Program. When transferring ownership of a photovoltaic power plant, the new operator must apply for a new license and the previous owner must annul the original license. Unless the technical conditions under which the original license was granted change, the amount of support remains the same. The new operator loses the right to said support when the previous license expires and, at the same time, a new one is not issued.

If you would like to know more about the changes to the Czech Act on Investment Companies and Investment Funds or about the green tax in the Czech Republic, please do not hesitate to contact the experts of WTS Alfery, the exclusive representative of WTS Global for the Czech Republic.

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