No advertisement tax

The 2025 Hungarian autumn tax package originally stated that from 1 July 2026 a 7.5% advertising tax would be reintroduced on advertising revenues above 100 million HUF, from which the budget expected around 10 billion HUF in additional income. The system would have operated in a progressive, banded way, with tax exemption on the first 100 million HUF of revenue, partly addressing previous EU competition law concerns.

In April 2026, however, a government decree decided that the advertising tax rate will remain at 0%, so the previously planned reintroduction will not take place. According to the legal justification, the decision is based on the economic effects of the war environment and the need to avoid further increasing the burden on businesses.

The new government also plans to reduce or eliminate the retail tax and phase out other sector-specific special taxes.

Changes related to the SZÉP card

Amounts credited to the SZÉP card may be used for the purchase of cold food products only until 30 April 2026. This temporary option applies to the period from 1 December 2025 to 30 April 2026 and affects the accommodation sub-account. The preferential use covers prepared foods, bakery products, meat, and basic foodstuffs.

As this option will cease from early May 2026, we recommend amending fringe benefit policies (where this temporary option is expressly included), ensuring appropriate configuration of fringe benefit systems, and informing affected employees in a timely manner.

Changes to simplified employment

Data related to simplified employment (Hungarian abbreviation: EFO) can now be queried electronically. Through the mobile application of the Hungarian tax authority, the client portal (ÜPO) or eBEV, both employees and employers may track the number of days already worked. This allows verification of compliance with the annual 120-day limit, even prior to registration.

As a result of the government change, significant modifications to the Hungarian tax system are expected, which may substantially reshape companies’ tax and regulatory obligations. Should you require expert support in navigating this evolving landscape, please request a proposal from our tax consulting team.

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A contradictory and intricate area

Recent CJEU case-law clearly illustrates the complexity of the VAT treatment of transfer pricing corrections:

• In C‑726/23 Arcomet-case, the Court concluded that, subject to certain conditions, even adjustments intended to ensure a guaranteed profit margin may fall within the scope of VAT.
• By contrast, the Advocate General’s Opinion in C‑603/24 Stellantis-case emphasises that profit sharing, in itself, cannot be regarded as consideration for a service.

The common message is that the VAT treatment of transfer pricing adjustments cannot be handled mechanically: the decisive factors are always the economic substance of the legal relationship and the contractual structure.

How to account for year-end transfer pricing adjustments

In Hungary, retrospective transfer price adjustments may be carried out in several ways:

• by amending invoices retroactively,
• by adjusting consideration through an accounting document, or
• by making a corporate income tax base adjustment only.

The chosen technique is not merely an administrative formality; it also affects the precise point within the arm’s length range to which the adjustment must be made.

A recent modification of the Hungarian legal framework introduced a more favourable interpretation: applying the median is no longer automatically required when the adjustment is made via an accounting document. At the same time, the timing of the adjustment has become more stringent: from 2025 onwards it must be performed no later than the balance sheet preparation date.

Applying the arm’s length principle is relevant not only for corporate income tax but also for other income-type taxes, which further increases the importance of appropriate documentation.

A new approach to transfer pricing adjustments and indirect taxes

The key difficulty in the VAT treatment of transfer pricing adjustments is that corporate income tax and VAT follow fundamentally different logic. While the former is designed to allocate profits, VAT taxes the consideration for specific economic supplies. Earlier professional approaches presumed that a VAT correction could arise primarily where a direct link existed between the adjustment and a specific transaction. However, Member State practices may differ, resulting in enhanced interpretative and compliance risks for companies.

The Arcomet-judgment: rethinking the concept of consideration

One of the core messages of the Arcomet-case is that profit‑based pricing mechanisms do not automatically exclude tax obligation. Where the contract specifies particular services and the pricing mechanism is clear and mandatory, the balancing payment may become part of the consideration for the service. At the same time, the Court reaffirmed that the existence of tax liability requires an objective and direct link between the supply and the payment, to be assessed in light of all relevant circumstances.

The judgment also highlights the practical conditions of exercising the right to deduct VAT. This right is not automatic: the tax authority may request further evidence proving that the service was actually supplied and served the taxable activity of the taxpayer. This makes the following documents indispensable, particularly for intra‑group services:

• detailed contractual background,
• performance confirmations,
• internal reports,
• cost allocation calculations.

The Stellantis-case: the need to move beyond a purely case-by-case approach

The Stellantis-case shows that the economic substance of the arrangement is decisive in determining the VAT treatment of transfer pricing adjustments. In the model examined, intra-group purchases were made at a predefined reference price, and at year‑end a retrospective adjustment was carried out based on actual costs and a target profit margin. The legal dispute centred on whether these balancing payments modified the taxable amount of previous supplies or should instead be viewed as financial settlements intended to ensure group‑level profitability.

The lesson of the case is that price corrections refining the consideration for the original transactions must be distinguished from adjustments serving a profit reallocation function. The former may trigger a VAT base modification, while the latter typically fall outside the scope of VAT.

For proper classification, the level of detail in the contractual pricing mechanism and the degree to which the adjustment is linked to specific supplies are determining. This requires companies to design their documentation and invoicing practices consciously.

Transfer pricing adjustments and customs valuation

Transfer pricing adjustments may also be relevant for customs valuation. According to the latest direction in EU case-law, profit‑driven adjustments may affect customs obligations even without modifying the price of specific transactions, creating additional compliance and administrative burdens for companies.

In light of recent CJEU decisions, a comprehensive review of corporate groups’ current transfer pricing and invoicing practices may be warranted. Coordinated management of corporate income tax and VAT requirements, clear contractual definition of pricing mechanisms, and detailed documentation of supplies have become essential to mitigate risks – especially given the increasing scrutiny of the authorities. Should you require professional support regarding the VAT treatment of transfer pricing adjustments, the transfer pricing advisers of WTS Klient Hungary are ready to assist.

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Milestones in the introduction of information exchange

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

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

More effective action against international tax evasion

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

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

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

Who is subject to the reporting obligation?

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

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

Which data and activities are covered by the obligations?

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

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

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

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

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

Globalising data reporting: information exchange beyond the EU

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

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

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

Special tax obligations imposed on digital platforms

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

Current and future VAT rules

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

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

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

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

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

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

Retail tax

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

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

Supervisory fee

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

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

This article provides general information and does not constitute advice.

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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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ITR World Tax 2026

In mid-October 2025, ITR (International Tax Review) published its current rankings of the world’s most recognised tax consulting firms and tax practitioners. ITR World Tax 2026 lists WTS Klient in Tier 2 in three categories:

• General corporate tax: Tier 2
• Indirect tax: Tier 2
• Transfer pricing: Tier 2

ITR World Tax Leaders 2026

In the country-by-country ranking of the world’s best tax practitioners, ITR World Tax Leaders 2026, five of our advisers were included again this year, similarly to last year.

• Réka Kiss, Director at WTS Klient, received a “Highly regarded” rating in the general corporate tax category
• Tamás Gyányi, Senior Partner at WTS Klient, received a “Highly regarded” rating in the indirect tax category
• András Szadai, Partner, Head of Tax Services at WTS Klient, received a “Highly regarded” rating in the indirect tax category
• Tamás László, Director at WTS Klient, received a “Rising star” rating in the indirect tax category
• Zoltán Cseri, Senior Manager at WTS Klient, received the title of “Rising star” in the indirect tax category

According to the ranking, Tamás Gyányi and András Szadai are among the nine best indirect tax advisers in Hungary, while Réka Kiss is one of the four best general corporate tax experts in the country. Tamás László and Zoltán Cseri were named “Rising Stars” for the third time. A total of eight young tax professionals in Hungary received this title this year.

Meet WTS Klient’s renowned tax advisers!

Réka Kiss started her professional career as a tax adviser assistant at Noerr Hungary before joining the WTS Klient team, where she currently holds the position of tax director. She spent a year in the VAT department of WTS Germany’s Munich office. Her main areas of expertise are global expatriate tax services, mergers and due diligences before acquisitions.

After his years at a Big4 company, Tamás Gyányi joined Klient in 2004. His name is synonymous with the establishment of the company’s tax consulting division, which has since become one of the strongest bastions of WTS Klient. In 2014, he was appointed a tax partner of the firm, then in March 2022, a senior partner of the tax advisory, payroll and later the HR services divisions. He has been ranked as “Highly regarded” in the ITR World Tax Leaders 2026 for the 10th time, meaning he has been awarded this title every year since 2017.

András Szadai started as a trainee in the tax team of Klient in 2006, after his college studies. He worked as a tax adviser in London for two years and gained experience also in the transfer pricing group of WTS in Munich for 4 months. Since 2022 he has been head of the tax consulting division of WTS Klient as a partner.

Tamás László economist, tax consultant and certified VAT expert. He mainly deals with VAT issues and tax representation for international companies, handling tax and transfer pricing advice, VAT registration, tax audits, tax planning and due diligence, and he is an outstanding expert in digital solutions in taxation and the related IT-developments.

Zoltán Cseri started his professional career as an intern at WTS Klient. He is a tax consultant, a certified tax adviser, qualified transfer pricing expert and environmental product fee expert, so his main areas of expertise include VAT, transfer pricing and expatriate tax advice, as well as environmental product fee and EPR consulting.

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In what cases can companies decide to initiate a voluntary liquidation?

The voluntary liquidation procedure can be initiated for several reasons, provided that the company is not insolvent. Typically, changed market conditions, cost optimisation in the case of companies with an international background, or changes in legislation prompt owners to terminate their companies through voluntary liquidation.

Voluntary liquidation cannot be decided, and voluntary liquidation that has already begun cannot be completed if the court, prosecutor’s office, or investigating authority conducting criminal proceedings notifies the company or the commercial court that criminal proceedings may be brought against the company.

Voluntary liquidation in Hungary is one of the possible forms of termination without a legal successor, the accounting tasks of which are set out in Hungarian Government Decree 72/2006. (IV. 3.), but in matters not regulated by the government decree, the provisions of the Hungarian Act on Accounting shall continue to apply.

Planning the voluntary liquidation

During the voluntary liquidation procedure, the company will have several tax and accounting obligations that differ in terms of timing and content from those fulfilled during standard operations. It is advisable to consider these before deciding on voluntary liquidation and to plan the tasks and obligations to be performed.

8 aspects to consider before deciding on voluntary liquidation

1. One of the most important questions is whether the owner wishes to terminate the company through standard voluntary liquidation or so-called simplified voluntary liquidation. The latter option is available to companies that are not subject to an audit and can complete the voluntary liquidation within 150 days.

2. The resolution must specify the start date of the voluntary liquidation and, in the case of standard voluntary liquidation, the liquidator. From the start date of the voluntary liquidation, the managing director’s mandate ceases and from then on, the liquidator represents the company.

3. In the case of simplified voluntary liquidation, it is not necessary to appoint a liquidator, as the senior executive of the company performs this role.

4. It is advisable to set the start date of the voluntary liquidation as the first day of the financial year, so that the company does not have to prepare an additional accounting close due to the start of the voluntary liquidation, and the financial statements can be the financial statements ending the activity as well. If the start date of the voluntary liquidation is not the first day of the usual financial year, the financial year of the voluntary liquidation is 12 calendar months from the start date of the voluntary liquidation.

5. Simplified voluntary liquidation may involve less and faster administration and, in some cases, even lower costs, as it is not necessary to have a lawyer prepare the legal documents to be submitted to the Hungarian Court of Registration.

6. Before starting the voluntary liquidation procedure, it is advisable to review the company’s books in detail. The composition of assets and liabilities and the amount of outstanding receivables and liabilities must be examined. This is necessary because during voluntary liquidation, the company must settle all receivables and liabilities it has towards third parties.

7. During voluntary liquidation, it is advisable to submit a request for a reduction in tax advances payable to the Hungarian tax authority and local authorities if, based on calculations, the planned tax will be less than the tax advances payable. This will also reduce the amount of any subsequent overpayment.

8. If the voluntary liquidation is also subject to an audit obligation, it is advisable to consult with the auditor before starting the procedure in order to comply with the deadlines.

Stages of the voluntary liquidation procedure

1. Commencement of voluntary liquidation

Within 30 days of the start of the procedure, the company must prepare a final financial statement with the day preceding the start of the procedure as the balance sheet date, which must also be audited in the case of a company subject to audit. In addition, the preparation and approval of the resolution accepting the financial statement must also be planned within the 30-day deadline.

In addition to the financial statement, the liquidator is also responsible for preparing the final tax returns (VAT, corporate tax, contributions, and local business tax) and data reporting:

• notification to the local authority within 15 days of the start date of the voluntary liquidation,
• in the case of simplified voluntary liquidation, notification to the Hungarian tax authority using form T201T, which must also be completed within 15 days. (In the case of standard voluntary liquidation, lawyers fulfill this notification obligation to the Hungarian Court of Registration.)

2. Tasks to be performed during the voluntary liquidation period

Creditors may submit their lender demands within 40 days of the announcement of the commencement of voluntary liquidation, which the liquidator shall record in a register and forward to the Hungarian Court of Registration. If there is a discrepancy between the receivables reported and the values shown in the company’s books, the liquidator must prepare a corrected opening balance sheet for the voluntary liquidation as of the start date.

Tasks of the liquidator

• termination of the company’s activities
• collecting receivables
• satisfying creditor claims
• terminating existing contracts
• terminating employment contacts
• ensuring the preservation of tax and accounting documents and records for the period prescribed by law, including for the period following the voluntary liquidation
• selling assets, if necessary
• distribution of remaining assets among the owners

This period lasts from the start date of the voluntary liquidation until its completion, during which time the company must comply with the tax and contribution returns that are customary in the standard course of business.

3. Completion of the voluntary liquidation procedure

Standard voluntary liquidation may take up to three years. During this period, the company must complete standard year-end closings for each financial year. (In the case of simplified voluntary liquidation, this may take up to 150 days.) If standard voluntary liquidation is not completed within three years, involuntary deregistration will be conducted.

A decision by the owner is sufficient to complete the voluntary liquidation; no separate members’ resolution is required.

The company is subject to a reporting obligation also towards the local authority, which must be fulfilled within 15 days of the closing date of the voluntary liquidation.

Upon completion of the voluntary liquidation procedure, the liquidator is required to ensure that the following documents are prepared:

• final tax returns
• financial statement concluding the voluntary liquidation
• proposal for the distribution of remaining assets
• resolution of the members’ meeting

In the case of standard voluntary liquidation, the above documents must be submitted simultaneously within 60 days of the closing date of the voluntary liquidation.

Companies opting for simplified voluntary liquidation have a total of 150 days to complete the voluntary liquidation and submit the above documents, which must be prepared based on predefined document templates. These are available on the website of the Hungarian government website (available in Hungarian).

Tax authority must also be involved

In the case of simplified voluntary liquidation, an additional task is to provide the tax office with information on the closing date of the voluntary liquidation on the T201T form. If the simplified voluntary liquidation is completed with the decision to continue the company’s operations, this must also be reported on this form.

If the company is unable to complete the simplified voluntary liquidation within 150 days, it must switch to standard voluntary liquidation under the general rules.

During the voluntary liquidation procedure, it is important to complete all tax returns and data reporting by the deadline, as failure to do so may result in the Hungarian tax authority imposing a penalty on the liquidator.

After the above obligations have been fulfilled, the Hungarian tax authority has the option of initiating a retrospective tax audit. The company can only be dissolved if the tax authority issues a certificate to the Hungarian Court of Registration stating that it has no debts or open tax cases. The Hungarian tax authority has a maximum of 90 days to issue this certificate in the case of standard voluntary liquidation and 30 days in the case of simplified voluntary liquidation.

After the certificate has been issued, the company registry court will delete the company from the company register. After deregistration, the company’s bank accounts can be closed and, at the same time, the assets specified in the asset distribution proposal can be paid out to the owners.

Voluntary liquidation is the closure of a company’s activities without a legal successor, which involves complex accounting and tax tasks. The owners can choose between a standard or simplified procedure, taking into account obligations, deadlines and costs. The voluntary liquidation procedure requires planning, precision, and adherence to deadlines, so it is definitely worth involving an expert. The accounting professionals at WTS Klient Hungary are at your disposal!

This article provides general information and does not constitute advice.

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In such high-stakes situations with significant tax implications, a binding tax ruling (feltételes adómegállapítás) can offer a solution. This is the legal instrument under which the Minister responsible for tax policy – based on a detailed factual description submitted by the applicant – issues a binding determination in advance as to the tax consequences of a specific transaction or a contract template.

The importance of this instrument has been reaffirmed by the Curia (Hungary’s Supreme Court) in recent years. In a precedent-setting case, the Court held that the binding force of a binding tax ruling only ceases if the tax authority conducting the audit can prove a material difference in the facts and/or applicable tax law. Provided that both the factual circumstances and the legal framework remain unchanged, the tax authority may not deviate from the content of the ruling.

From the submission of the application for a binding tax ruling, an audit moratorium takes effect for the specific transaction until the 15th day following the final and binding decision. Thereafter, the binding force of the ruling lasts until the last day of the fifth tax year following its issuance, which can be extended once, by a further two years.

These provisions not only ensure legal certainty but can also facilitate the implementation of major projects. For instance, in the context of bank financing, it is a strong argument if the project’s tax risk can be officially reduced to a minimum. The long-term certainty is, however, counterbalanced by notably high procedural fees.

Rising procedural fees and the option of preliminary consultation – 2025 amendments

The summer 2025 tax package introduced further changes to the legal framework of binding tax rulings. Procedural fees have increased once again: the fee for the standard procedure is now HUF 10 million, for the expedited procedure HUF 14 million, and for rulings concerning a contract template HUF 12 million (HUF 16 million if expedited). As of 1 August preliminary consultation is available again at a fee of HUF 1 million. According to the legislator, the rising fees are intended to cover the costs of processing increasingly complex cases; however, they may prompt more businesses to reconsider whether to file an application at all.

The rules on preliminary consultations have also been clarified: the tax authority’s position expressed during the consultation, recorded in writing – while not legally binding – may serve as a starting point during the subsequent application process. This strengthens the practical value of the instrument, as the taxpayer does not start entirely “from scratch” in the official procedure. This approach can save both costs and time, while allowing the formal ruling application to be submitted with better prospects.

Other key amendments of the 2025 summer tax package are summarised in our following article: Summer 2025 Tax Package Adopted – WTS Klient.

Deadlines, remedies, and further considerations

The procedure is formal and strict: the general processing time is 90 days (60 days in expedited cases). No appeal is available; only judicial review may be sought. Professional (tax advisor) representation is mandatory during the process.

The application may relate to a future transaction, a transaction not qualifying as future (in which case only certain taxes are covered), a contract template, or VAT apportionment. Only a well-defined and unambiguous set of facts may be the subject of the application; general tax advice cannot be requested within this framework. The application cannot be accepted if there is a risk of past tax law violation or tax avoidance. Nor can it concern purely accounting questions.

Is it worth applying for a binding tax ruling?

The binding tax ruling remains one of the strongest legal certainty instruments in the Hungarian tax system, especially for high-value, complex, or cross-border transactions. While the 2025 summer tax package has increased the costs of the procedure, the clarification of preliminary consultation rules has made the preparatory stage of the process more transparent and effective.

Given the current level of procedural fees, it is advisable to base the decision on a thorough cost–benefit analysis, and in most cases, to first assess the chances of success via a preliminary consultation. With proper preparation and professional support, binding tax rulings can still provide the stable legal environment in which businesses can confidently make strategic decisions.

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In our previous newsletter (https://wtsklient.hu/en/2025/06/13/failed-data-reporting/), we highlighted that NAV is taking a stricter stance on failures to comply with online invoice reporting obligations, and that even minor administrative errors can now trigger sanctions. More recently, the authority has assumed a more proactive role in oversight, introducing targeted reconciliation procedures to identify inaccuracies.

What should companies pay attention to?

During these reconciliations, NAV primarily checks whether the data submitted by taxpayers matches the data recorded in its system. Affected businesses receive a notification if discrepancies are found in their reporting. Taxpayers then have 15 days from receipt of the notification to correct and clarify the relevant data. After the deadline, NAV will review the submitted corrections and notify the taxpayer of the final outcome of the reconciliation.

Reconciliation procedures are expected in the following areas:
• Discrepancies between reported and fulfilled invoice data
• Anomalies related to VAT deduction rights

What to do if your company receives a notification?

If NAV detects discrepancies, taxpayers may correct the data through self-revision or by amending the invoice reporting. It is crucial to act promptly, as failure to address discrepancies in a timely manner may result in serious consequences, including tax penalties.

It is important to note that participation in the reconciliation process is mandatory for taxpayers. Ignoring NAV’s notification or request may lead to a default penalty. The fine increases progressively: failure to meet the initial 15-day deadline can result in a HUF 300,000 fine. If the second 15-day deadline is also missed, the penalty increases by an additional HUF 100,000. Should the taxpayer fail to respond to the third request within the set deadline, the fine may reach as much as HUF 500,000.

In our article, we highlight the key aspects of the Hungarian Tax Authority’s increasingly intensive data reconciliation procedures. If you have any questions regarding the topics discussed, the experts of WTS Klient Hungary is always ready to assist you with professional support.

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.

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