The most important changes in the autumn tax package

Value Added Tax (VAT)

Group taxation: From 20 December 2025, the rules on the appointment of the group representative have been clarified. If the group representative ceases to exist, the members must appoint and report a new representative within 15 days. Failure to do so will result in the Hungarian Tax Authority (HTA) automatically appointing the member with the highest tax performance as the representative. If the representative becomes subject to liquidation or compulsory strike-off proceedings, its mandate will automatically terminate.

New provisions also specify the procedure to follow after the termination of the VAT group where the representative has ceased to exist without a legal successor.

Liability rules are tightened: group members and related parties are jointly liable for breaches of obligations under the VAT Act, including tax penalties and late payment interest.

Individual VAT exemption: The turnover threshold for individual VAT exemption will increase in several steps: to 20 million HUF from 1 January 2026 to 22 million HUF from 1 January 2027, and to 24 million HUF from 1 January 2028. The VAT exemption may be opted for even if it previously ceased due to exceeding the threshold and the two-year restriction on re-electing has not yet expired, provided that the taxpayer falls within the new, higher threshold.

Access to eVAT data: From 20 November 2025, the successor entity can access the data of VAT returns filed by its predecessor on the eVAT platforms (via web interface or M2M connection) for tax periods starting on or after 1 January 2025. Self-revisions may also be carried out exclusively for these periods, using the same electronic interface previously used by the predecessor. This rule does not apply to all types of succession, for example, the transfer of agricultural holdings or the transfer of functions between institutions (central government or local authorities).

Extension of M-sheet data reporting: From 1 July 2026, the obligation to provide data on the M-sheet will be extended. Taxpayers will be required to report input VAT deductions broken down by tax rate. In cases of proportional deduction, data has to be reported on the proportionally deductible amount, which may be submitted in aggregated form. The new rules will also apply to correcting and cancelling invoices, as well as to invoices that include the offsetting of advance payments.

Corporate income tax (CIT)

R&D tax base allowance: As of 10 December 2025, the threefold R&D tax base allowance may be claimed not only where the taxpayer carries out R&D activities jointly with a higher education institution, the Hungarian Academy of Sciences or another research institute or research centre, but also where the taxpayer enters into a cooperation agreement with a business entity that is wholly owned by any of these institutions and performs knowledge utilisation tasks.

R&D tax credit: From 20 November 2025, if the taxpayer has opted for the R&D tax credit instead of the R&D tax base allowance, this decision may be modified no earlier than the fifth tax year following the election, by notifying the tax authority (instead of the previous rule requiring six years).

Another change, effective from 20 December 2025, provides that where R&D activities are carried out jointly with other institutions, the tax credit may amount to:

• up to 100% of the eligible costs for basic research,
• up to 50% of the eligible costs for applied research,
• up to 25% of the eligible costs for experimental development.

From 20 December 2025, the R&D tax credit may also be applied where the taxpayer enters into a cooperation agreement with companies wholly owned by a higher education institution, the Hungarian Academy of Sciences, or another research institute/centre that perform knowledge utilisation tasks.

Development tax allowance: From 1 January 2026, a development tax allowance may be claimed for investments aimed at increasing production capacity for clean technology products or their components (e.g. solar panels, wind turbines, heat pumps, batteries and the raw materials required for these).

The allowance, calculated at present value, may amount to:

• In Budapest: up to 15% of the costs
• Outside Budapest: up to 35% of the costs.

The tax allowance may be applied in the tax year following the commissioning of the investment and for a further 12 years, but no later than the end of the 16th tax year following the year of notification. The taxpayer may also choose to apply the allowance already in the year of commissioning.

Important change: from 2026, the development tax allowance will not be available for strategic investments aimed at zero net emissions.

Tax allowance for environmental investments and renovations: From 1 January 2026, a new tax allowance may be claimed for environmental investments and renovations of at least HUF 100 million, provided that the purpose of the investment is:

• the elimination of environmental damage,
• the rehabilitation of degraded habitats and ecosystems,
• the protection or restoration of biodiversity, or
• climate change mitigation and adaptation through nature-based solutions.

Amount of the allowance:

• 100% for environmental damage remediation and rehabilitation,
• 70% for ecosystem protection and nature-based solutions,
• but no more than the HUF equivalent of EUR 30 million.

The allowance may be applied in the tax year of commissioning (or the following year) and for a further five tax years.

Tax advance payments: From 1 January 2026, the threshold for monthly tax advance payments will increase from HUF 5 million to HUF 20 million, based on the previous year’s tax liability. Below this threshold, advances will continue to be payable quarterly. The new rule will first apply to advances calculated for the 2025 tax year where the return is due after 31 December 2025.

GloBE

Simplified covered tax: From 20 November 2025, a new, more specific definition applies to the simplified covered tax. Under this definition, the simplified covered tax refers to the current-year income tax expense recognised in the consolidated financial statements of the MNE Group, including deferred tax (except for uncertain tax positions). Local business tax and innovation contribution are excluded if presented as other expenses in the financial statements. The simplified effective tax rate is calculated as the ratio of the simplified covered tax to the profit before tax reported in the Country-by-Country report.

Country-by-Country report and recognized financial statements: The law defines the concepts of recognized Country-by-Country reporting and recognized financial statements. These definitions derive from the OECD regulatory framework, which were already applied in practice; the clarification does not result in substantive changes.

Substance-Based Income Exclusion: The application of the transitional relief table for substance-based income exclusion has been clarified. Accordingly, for a fiscal year beginning in the year indicated in Column A, the percentages shown in Columns B and C of the table must be applied.

Reporting of the top-up tax: Annex 7 of Act XXXVII of 2013 on the Rules of International Administrative Cooperation in Relation to Taxes and Other Levies (Aktv.) sets out the content and formal requirements for reporting (GIR). The report must include:

• data regarding the multinational enterprise group,
• exemptions and exclusions,
• jurisdictional effective tax rate and the calculation of the top-up tax.

Where a member of the MNE Group files the GIR abroad, the domestic group entity is exempt from the reporting obligation. To verify this, and in line with the DAC 9 Directive, tax authorities will exchange information automatically with jurisdictions concerned under the OECD Global Anti-Base Erosion (GloBE) Rules. If there is suspicion of incorrect or incomplete data exchange, the HTA will notify the competent foreign authority.

“Robin Hood” tax – Income tax of energy suppliers

Tax allowance for energy development investments: From 1 January 2026, taxpayers holding a distribution licence under the Electricity Act (Vet.) may claim an investment tax allowance for energy development projects commissioned in the tax year. The allowance may be applied in the year of commissioning and for the following five tax years. Its amount equals the difference between the eligible costs of the investment and the adjusted depreciation but cannot exceed 50% of this difference at present value.

Eligible costs include the acquisition cost of tangible and intangible assets serving the purpose of the investment, reduced by any non-repayable grants, contributions, or connection fees received.

Assets related to the investment must be operated for at least five years, and the professional indicators set out in the implementing regulation must be met. Upon request, the Hungarian Energy and Public Utility Regulatory Authority (MEKH) issues an investment incentive certificate confirming the fulfilment of these indicators.

The allowance may be applied for the first time in the tax year of 2026 for investments started after 31 December 2025.

Limitation: The total amount used as a tax allowance may not exceed 80% of the calculated corporate income tax for the year, after deducting the development tax allowance and the allowance for energy efficiency investments and renovations..

Personal Income Tax (PIT)

Tax exemption for compensation due to fraud: From 20 December 2025, credit institutions may reimburse, free of tax, any loss suffered by the injured party as a result of fraud or misuse of sensitive payment data (such as bank card details) used in connection with payment services.

Continuous tax advance declaration: From 1 January 2026, any tax advance declaration submitted in 2025 for the application of the allowance available to mothers raising three children will be treated by the employer or payer as a continuous declaration until the mother files a new one.

As of the same date, taxpayers entitled to the allowance for mothers raising three children or two children may also submit a continuous declaration for the application of these benefits. The employer or payer will continue to apply the declaration made for in-year application of the allowance without change, until the mother files a new declaration or requests its withdrawal.

There is no requirement to renew the declaration annually; a new declaration is only necessary if the data underlying the entitlement changes.

Declaration on family allowance: From 1 January 2026, if a mother submits a tax advance declaration to apply the family allowance or the family social security contribution allowance, she may indicate her entitlement to the allowance for mothers raising four, three or two children.

The employer or payer will treat the mother's declaration requesting application of the allowance as a continuous tax advance declaration until she files a new declaration.

Increase in lump-sum expense ratios: From 1 January 2026, individual entrepreneurs applying the lump-sum taxation regime for activities not specifically listed in the PIT Act may determine their taxable income by deducting a 45 percent expense ratio from their revenue. This ratio will increase to 50 percent as of 1 January 2027.

Tax equalisation for crypto transactions: From 1 January 2026, the tax value of losses from crypto-asset transactions may be carried forward indefinitely, provided the individual reports the loss in the PIT return for the year in which it occurred. Tax payable on income from crypto transactions declared for the current tax year or the two preceding years may be reduced by the tax value of any previously reported but not yet utilised losses from earlier years. To apply tax equalisation, taxpayers must maintain records that clearly show the cumulative amount of unutilised losses from crypto transactions for any given year. This figure must also be disclosed in the tax return as an informational item.

SZÉP-card food purchases: Between 1 December 2025 and 30 April 2026, amounts credited to a SZÉP Card may once again be used for purchasing cold food items.

Social Security

Long-term mandate relationship: As of 1 January 2026, a new form of engagement – the long-term mandate relationship – may also be registered with the tax authority. As a general rule, the monthly contribution base must equal at least 30% of the minimum wage.

Complex Legal Relationship Register (CLRR) and online administration: As of 1 January 2026, the CLRR digital platform will provide access to insurance, contribution and entitlement data managed by the National Health Insurance Fund (NEAK), the HTA and the Hungarian State Treasury. Reconciliation of healthcare contribution payments and health insurance entitlements, as well as the handling of disputed cases, can be carried out via the HTA's electronic interface or mobile application. The system will automatically forward relevant information to NEAK, including retroactive cancellations initiated ex officio in cases where the procedure is otherwise obstructed.

Social Contribution Tax

Tax liability of long-term mandate relationships: From 1 January 2026, long-term mandate relationships are also subject to social contribution tax, except where statutory exemptions apply. The tax base must equal at least 30% of the minimum wage.

Tax obligations of sole proprietors and partnerships: From 1 January 2026, the minimum base for social contribution tax for sole proprietors and partnerships will be the minimum wage. The current 112.5% multiplier will no longer apply. If the principal activity requires at least a secondary qualification or vocational training, the guaranteed minimum wage will serve as the base.

Where the entrepreneur does not work for the full month (e.g. commencing mid-month), the base is calculated pro rata, using one-thirtieth of the minimum wage or guaranteed minimum wage for each day.

Social tax liability for pensioners in their own right: From 1 January 2026, a social contribution tax liability will arise for pensioners in their own right claiming the personal income tax allowance based on the number of children, if the combined income forming the basis of the mothers' allowance exceeds four times the annual average wage. The social contribution tax is payable only on the portion of income exceeding this threshold.

Local taxes

Rights of lessees and buyers under retention of ownership: From 1 January 2026, lessee's rights and buyers' rights arising from retention of ownership will qualify as proprietary rights. If these rights are registered in the real estate registry, the holder of the right will be liable for the payment of building tax and land tax.

Duties

Duty-free waiver of member loans in liquidation: As of 1 January 2026, the waiver of a member loan during liquidation is exempt from duty if the company is ultimately struck off by the court of registration. The HTA will suspend the duty assessment for the duration of the liquidation and will automatically cancel it by way of notation upon deletion of the company. If the company is not struck off, the duty must be paid together with late payment interest.

Extension of the duty relief for replacement purchases in real estate acquisitions: As of 1 January 2026, when acquiring residential real estate, not only the chronologically closest sale of a dwelling may be taken into account. Instead, the taxpayer may choose the sale that results in the most favourable duty base from among disposals made within five years prior to the purchase (instead of three years) or within one year following the purchase.

As of 1 January 2026, the duty relief for replacement purchases may also be applied to the acquisition of a proprietary right connected to a dwelling (e.g. usufruct).

KIVA (Small business tax)

Entry conditions: From 1 December 2025, the entry thresholds will change as follows:

• Headcount limit: 100 employees
• Revenue limit: HUF 6 billion (calculated proportionally for shorter tax years)
• Balance sheet total: HUF 6 billion

The new thresholds apply to KIVA elections reported from 1 December 2025.

Termination of KIVA status: From 1 January 2026, KIVA status will cease if:

• Revenue exceeds HUF 12 billion (as of the day before exceeding),
• Headcount exceeds 200 employees (as of the last day of the month in which the change occurs)

KIVA base and rate: From 1 January 2026, when determining the KIVA base, the minimum wage must be taken into account at 100% (instead of the previous 112.5%) if the personnel-related expense per member is lower than this amount. The tax rate remains unchanged: 10% of the tax base, which replaces corporate income tax and social contribution tax.

Tax procedures

Unified quarterly filing for sole proprietors: From 1 January 2026, sole proprietors who opt for the entrepreneurial income taxation regime will also be required to submit their tax and contribution returns on a quarterly basis. At the same time, they must pay both social security contributions and social contribution tax for the relevant quarter.

Filing obligation during suspension of sole proprietorship: From 1 January 2026, sole proprietors under the PIT Act will no longer be required to submit an extraordinary tax return for any period not covered by a regular filing, provided their business activity was fully suspended throughout that period.

Notification to jointly liable parties: As of 20 November 2025, upon request, the tax authority will provide information to a party jointly liable for a tax or public debt on the amounts collected from any of the liable parties up to the date of the notification, whether through voluntary payment or enforcement.

Reduction of tax liabilities via request: From 1 January 2026, taxpayers may request a reduction of their tax liability by submitting an application instead of performing self-assessment amendment, if they consider that the underlying legal provision determining the liability is unconstitutional, conflicts with mandatory EU law, or – where based on a municipal decree – contradicts other legislation.

Restriction on VAT self-revisions after limitation period: From 1 January 2026, if a court issues a decision on a taxpayer's liability after the statute of limitations for tax assessment has expired, no VAT self-revision may be filed for the time-barred period if such correction would affect another taxpayer's VAT position.

Unified threshold for late payment interest: From 1 January 2026, the tax authority will no longer impose late payment interest on tax shortfalls if the amount - similar to balances on the taxpayer’s account - does not exceed HUF 5,000 for the given tax type.

Expansion of the HTA’s services: As of 1 October 2026, the following services will become available via the HTA’s Client Portal (ÜPO) and the mobile application (NAV-Mobil):

• access to current health insurance data,
• initiation of procedures related to health insurance status,
• access to data of the individual social security account and the European Health Insurance Card, and
• the ability to request a certificate confirming inclusion in the public database of taxpayers with no public debt.

Filing frequency for retroactive VAT registration: As of 20 November 2025, where VAT registration or a change notification is made retroactively, monthly VAT returns must be filed for all prior periods not covered by an existing return.

Automatic decision-making: As of 1 January 2026, the tax authority may conduct proceedings by way of automatic decision-making if

• the conditions for automatic decision-making set out in the Act on Digital Public Administration (DÁP Act) are met, or
• in proceedings initiated upon application or ex officio, all data required by the tax authority are available or can be obtained, and the decision does not require any discretion.

This procedural method may not be applied in appeal proceedings.

Right of disposition over an application: As of 20 November 2025, the applicant may dispose of their application not only until the decision becomes final, but until the tax authority takes action to notify the decision (for example, the application may be withdrawn up to that point).

Payment execution from blocked accounts: As of 20 November 2025, upon the taxpayer's request, the tax authority may authorise payments from a payment account blocked by HTA during any type of audit, including a compliance audit.

Allocation of voluntary enforcement payments: As of 1 October 2026, the tax authority will allocate a voluntary lump-sum payment made by the debtor through the EFER (Electronic Payment and Settlement System) to the bailiff's escrow account in accordance with the taxpayer's allocation statement.

Special tax on credit institutions and financial institutions

Increasing tax burden: As of 1 January 2026, the tax rate will rise from 7% to 10% on the portion of the tax base not exceeding HUF 20 billion, while the rate applicable to the amount exceeding HUF 20 billion will increase to 30% (previously 18%). In addition, the 2026 windfall tax liability may be reduced by purchasing government bonds, up to a maximum of 30% of the annual tax due (down from the previous 50% cap).

Retail tax

New tax brackets: As of 22 November 2025, the following new tax base brackets apply:

• 0%: up to HUF 1 billion
• 0.15%: HUF 1–50 billion
• 1%: HUF 50–150 billion
• 4.5%: over HUF 150 billion

The new brackets shall first be applied to the tax liability for the tax year starting in 2025. If the tax advance for 2025 calculated under the previous rules exceeds the amount calculated under the new brackets, the difference may be claimed electronically using form VISSZKA by calendar-year taxpayers until 31 December 2025, or by taxpayers with a different fiscal year until the last day of the tax year, or it may be applied in the annual tax return.

Suppliers of motor vehicle fuel: The sector-specific tax rate for fuel retail has been extended for 2026. If the taxpayer sells other products (e.g. food, beverages) in addition to fuel, the special rate applies to fuel, while the general rate applies to other goods. Services provided at fuel stations (e.g. car washes) are not considered retail activities, and therefore their value must be excluded from the tax base.

Motor vehicle tax and company car tax

Increasing tax rates: The rates of company car tax and motor vehicle tax for 2026 will be the amounts for 2025 adjusted (increased) by the change in the consumer price index for July 2025 compared to July 2024 (4.3%) as published by the Central Statistical Office, rounded in accordance with the provisions of the law. The new tax rates have been published on the HTA website.

Registration tax

Taxpayer: Where the owner and the operator of the vehicle are not the same person, the tax is payable by the owner. The amendment confirms the existing principle that the person liable for the tax is the one in whose name the registration application was submitted.

Tax rate: The registration tax is calculated based on a fixed multiplier determined by the tax authority and the vehicle's engine power and environmental classification. The fixed multiplier in 2026 is HUF 47,000.

Advertising tax

Mid-year reinstatement: The advertising tax will remain suspended until 30 June 2026; however, from 1 July 2026, tax obligations will be reinstated. For taxpayers with a calendar-year tax period, the 2026 tax year will run from 1 July to 31 December, therefore the tax base must be annualised, and the tax liability must be fulfilled for the proportionate part corresponding to the actual number of days in the tax year. A tax advance must also be determined for the 2026 tax year, of which half must be paid by taxpayers publishing advertisements, at their choice, either on 20 July or 20 October (or, in the case of a non-calendar tax year, by the 20th day of the seventh or tenth month of the tax year).

Penalties for failure to register, declare or file returns: From 1 January 2026, persons or entities – typically foreign – carrying out taxable advertising publication must register at the HTA within 30 days from the start of this activity using form T201, provided they are not already registered for any tax. (The previous deadline was 15 days.) This does not apply to private individuals who are not sole traders.

If the taxpayer fails to fulfil the registration obligation, the tax authority will first send a warning and then issue two further notices with deadlines for compliance. Failure to comply may result in a penalty of up to HUF 10 million per case. Upon completion of registration, the last penalty will be waived, and earlier penalties may be reduced or cancelled.

Advertisers who fail to fulfil their declaration obligation towards the client will first receive a notice from the tax authority to remedy the omission. If they do not comply, the HTA will impose a fine of HUF 500,000. Repeated failure with the same client may result in a fine of up to HUF 10 million, and for each subsequent failure, the amount of the fine will be doubled. Upon fulfilment of the obligation, the last penalty will be waived, and earlier penalties may be reduced. Possession of the declaration exempts the client from the obligation to pay the tax.

If the taxpayer fails to submit the tax return, the HTA may initiate a tax audit and determine the amount of tax by estimation.

Accounting

Transfer pricing adjustment: From 1 January 2026, in the case of voluntary transfer pricing adjustments, it will no longer be mandatory to apply the median value in the accounting records; it suffices for the adjustment to fall within the arm's length range. The accounting correction for the affected items (e.g. asset acquisition cost, revenue, value of services) may be carried out based on the agreement of the parties up to the date of preparing the financial statements. The new rule must be applied mandatorily in the financial statements for the business year starting in 2026, but it may also be opted for in respect of the 2025 business year.

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Should you have any questions concerning the above, our advisors will be happy to assist you.