Elevation of Emergency Decrees to Statutory Level, Wealth Taxation
Act XIV of 2026 on elevating to statutory level certain emergency decrees adopted in light of the armed conflict in the territory of Ukraine was promulgated in Issue 44 of the Hungarian Gazette on 9 May 2026 (effective as of 14 May 2026). Under the Act, a number of tax-related provisions previously introduced by government decrees during the state of emergency have been incorporated into statutory law. These include, inter alia, the personal income tax and social contribution tax exemption related to representation expenses, the reduced tourism contribution applicable to restaurants and confectioneries, the amended special tax rules applicable to credit institutions and energy suppliers, as well as the maintenance of the 0% rate of advertisement tax.
In addition, based on a Government decision, the substantive re-regulation of wealth taxation and the tax regime applicable to fiduciary asset management structures is expected to begin in the near future.
In addition, based on a Government decision, the substantive re-regulation of wealth taxation and the tax regime applicable to fiduciary asset management structures is expected to begin in the near future.
With the entry into force of Act XIV of 2026, the tax-related provisions of government decrees issued during the state of emergency have been elevated to statutory level. The table below summarises the new legislative placement and key content of the respective provisions.
Tax provision / Statutory reference | Content |
|---|---|
Tax exemption for restaurant and confectionery representation
| Representation provided in the form of hospitality services (food and beverages) in restaurants or confectioneries is exempt from personal income tax and social contribution tax up to 1% of the taxpayer’s annual revenue recognised for the tax year, capped at HUF 100 million. The payer is required to pay tax advances during the year if the value of representation exceeds HUF 100 million either cumulatively during the tax year or within a given quarter. The definitions of “restaurant” and “confectionery” are based on registration pursuant to Government Decree No. 210/2009 (IX. 29.). |
Tax exemption for alcohol products bearing a „pálinka” tax seal
| Alcohol products produced in an excise warehouse, purchased directly from such warehouse, and bearing a „pálinka” tax seal are tax-exempt when provided as representation, business gifts, or small-value gifts. Condition: proper records must be maintained regarding the source of acquisition and the use of such products. |
Deductibility of service charges from the KIVA base
| When determining the KIVA tax base, service charges may be excluded from personnel-related expenses. This provision is first applicable for the 2026 tax year. |
Special tax liability of credit institutions and financial enterprises
| The special tax rate for the tax year starting in 2026 is 10% on the portion of the tax base up to HUF 20 billion, and 30% on the portion exceeding HUF 20 billion. In the case of the government bond purchase allowance, the reduction equals 10% of the increase in the nominal value of government bond holdings, capped at 30% of the special tax payable for the tax year. |
Special tax on energy suppliers
| Taxpayers – defined under Section 10 point 1, subpoints 1.1-1.6 and 1.8 – subject to the income tax of energy suppliers (Robin Hood tax) under the Act LXVII of 2008 are also subject to this special tax. Tax base: revenue from income-taxable activities for the 2024 tax year. Rate: 0.5% Cap: 50% of the 2024 income tax base. Filing and payment deadline: last day of the third month of the tax year starting in 2026. |
Reduced excise duties on price-regulated fuels
| Reduced excise rates apply as follows: ESZ-95 gasoline (not meeting ESZ-98 quality standard): HUF 139,550 per 1,000 litres; Diesel (CN code 2710 20 11): HUF 128,280 per 1,000 litres; Diesel released from the strategic reserves of the Magyar Szénhidrogén Készletező Szövetség (Hungarian Hydrocarbon Stockpiling Association) (CN code 2710 19 44): HUF 128,280 per 1,000 litres. |
Tourism contribution – restaurants and confectioneries
| For restaurant and confectionery services (as defined in Annex 4, points 1 and 3, respectively, of Government Decree No. 210/2009), the tourism contribution rate is reduced from 4% to 2%. This measure qualifies as de minimis aid. |
Advertisement tax
| The 0% advertisement tax rate is maintained for an indefinite period. |
Expected Legislation: Wealth Taxation and Fiduciary Asset Management
Pursuant to Government Resolution No. 1147/2026 (V. 14.), published in Issue 49 of the Hungarian Gazette, the Government has ordered the preparation of legislation aimed at establishing the legal framework for wealth taxation, and abolishing the tax exemption applicable to fiduciary asset management (i.e. the Hungarian equivalent to trust) structures.
At this stage, two key areas requiring particular attention can already be identified:
- Wealth Taxation: The introduction of a wealth tax has been regularly discussed both during the campaign period and in earlier professional debates; therefore, the initiation of legislative work is not unexpected. However, the detailed regulatory framework remains unclear and involves a number of open questions. Key open questions include the scope of taxpayers, the categories of taxable assets (e.g. real estate, financial assets, shareholdings, business interests, works of art), the methodology for determining the tax base (market value, book value or estimated value), the valuation framework (state valuation, self-assessment or potentially banded approaches), and the administrative and IT infrastructure required for implementation (reporting obligations, tax authority capacities, data systems).
These issues present significant legislative, administrative and practical challenges, and will substantively shape both the scope and the effective burden of the tax. From the perspective of individuals and family wealth structures holding substantial and diversified asset portfolios (real estate, securities, participations), the detailed rules may materially impact existing wealth planning and tax strategies.
- Fiduciary Asset Management: Since its introduction in 2014, the Hungarian “trust” regime has so far provided an attractive tax planning vehicle, particularly for succession planning, asset protection and long-term wealth structuring. The removal of the current tax exemptions may significantly reshape the domestic fiduciary asset management market and may necessitate a review of existing structures.
A key question will be whether transitional rules will be introduced for existing fiduciary arrangements.
Given that the deadline for preparing the legislative proposal is 5 June 2026, a draft is expected to be published shortly. Affected private individuals and wealth structures are advised to proactively review their current positions and, once the draft legislation is released, promptly assess the necessary steps.
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We trust that this newsletter provides a useful overview of the changes affecting emergency decrees. We continue to closely monitor legislative developments and will keep our clients informed of any further changes.
Should you have any questions in relation to the above, our advisors remain at your disposal.
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