Tax Newsletters 2025
You can read here the latest tax newsletters of the Hungarian office of Forvis Mazars published in 2025. We would like to inform our clients and partners about actual tax news and changes.
New Transfer Pricing Regulation
The Ministry for National Economy (‘NGM’) has submitted the new transfer pricing regulation for public consultation.
It seems that in 2025 a new chapter will begin in the local regulation of transfer pricing: the previous regulation (32/2017. (X. 18.) NGM Decree on the documentation obligation related to determining the arm's length price) will be replaced by an entirely new decree. The proposed amendments aim to ensure that transfer pricing documentation is prepared in a way that facilitates more efficient audits by tax authorities, enabling targeted risk assessments and streamlined selection of taxpayers for inspection. According to the current draft version, certain points will result in administrative simplification, while other areas will increase complexity and workload.
It seems that in 2025 a new chapter will begin in the local regulation of transfer pricing: the previous regulation (32/2017. (X. 18.) NGM Decree on the documentation obligation related to determining the arm's length price) will be replaced by an entirely new decree. The proposed amendments aim to ensure that transfer pricing documentation is prepared in a way that facilitates more efficient audits by tax authorities, enabling targeted risk assessments and streamlined selection of taxpayers for inspection. According to the current draft version, certain points will result in administrative simplification, while other areas will increase complexity and workload.
Tax saving opportunities in connection with royalties
Many businesses may not be aware that, under certain conditions, they may reduce their tax liabilities based on the profit or revenue from licensing software developed within their business. Yet, royalty-related tax benefits are not limited to corporate income tax (‘CIT’), similar advantages may also be available under local business tax and, indirectly, under the innovation contribution. However, a thorough review of the relevant statutory requirements (including international regulations, where applicable) is crucial, as claiming these benefits may involve several pitfalls.
Significant increase in EPR fees
As of 1 October 2025, significant changes have been introduced to the extended producer responsibility (EPR) fees in Hungary. According to EM Decree 28/2025 (IX. 22.) amending EM Decree 22/2024 (XI. 28.) on the establishment of waste management-related institutional fees, their application conditions and payment rules for 2025, fee levels have been substantially increased across multiple product and material streams.
Attention: Important deadline! Choosing to enter into corporate income tax groups until 20 November
20 November 2025 is the deadline until which company groups may submit their application to the Tax Authority for establishing a corporate income tax group for the 2026 business year, or in the case of an existing group, to dissolve a corporate income tax group it. Applications to join an existing group can be made also until that date. Companies that miss the above deadline will have to wait a whole business year for another opportunity.
The deadline for submitting refund applications for VAT paid abroad is approaching
Domestic tax subjects entitled to deduct VAT have an opportunity until 30 September 2025 to claim VAT refunds on the basis of invoices in 2024 with respect to purchases made in other member states of the European Union, and outside the European Union. After this peremptory deadline, the right to the refund is forfeited!
Critical Updates on FDI Rules – What Foreign Investors Need to Know
Foreign investors may face extended timelines for acquiring ownership in Hungarian strategic companies – key considerations for transactions involving foreign parties
Summer Tax Law Changes: What to expect in the second half of 2025 and from 2026 onward?
On 19 June 2025, Act LIV of 2025 on various tax obligations and on the amendment to certain tax laws (the “Act”) was promulgated. Some provisions enter into force in 2025, while others will only apply from 2026 onwards. This newsletter provides a summary of the most important changes.
Intensive Transfer Pricing Audits
In recent years, the National Tax and Customs Administration (NAV) has prioritized auditing transfer prices applied between related companies. The establishment of four new transfer pricing expert departments by NAV highlights the importance of this area. These new departments began their work on 1 March 2025 and, in addition to transfer pricing audits, they are also responsible for audits related to the global minimum tax. This latter area represents a new element in the recently published 2025 audit plan.
Key changes on indirect customs representation
Significant changes will take place regarding the VAT deduction rights on imports of goods. Starting 1 March 2025, stricter regulations will apply to indirect customs representatives and the import procedures they manage. This will also affect importing companies. Our newsletter summarizes the details of the new regulations and their impact on businesses.
Agreement reached on the ViDA package
Following extensive discussions, the Economic and Financial Affairs Council (ECOFIN) adopted the ViDA (VAT in the Digital Age) package on 5 November 2024, which could modify the EU value added tax (VAT) regulations in various areas. Our newsletter summarizes the package's implications and its impact on businesses.
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