Tax Newsletters 2026
You can read here the latest tax newsletters of the Hungarian office of Forvis Mazars published in 2026. We would like to inform our clients and partners about actual tax news and changes.
Large company taxation: 15% corporate income tax above EUR 500 million in revenue
On 27 October 2026, the Government submitted to Parliament the Bill on the amendment of certain acts in relation to corporate taxation (Bill No. T/931, hereinafter: the “Proposal”). From 1 January 2027, the Proposal would introduce a separate corporate income tax regime for large companies: taxpayers reaching the revenue threshold of EUR 500 million would be taxed at a rate of 15% under stricter tax base rules, while the 9% rate would continue to apply to all other taxpayers. Parliament may still amend the Proposal, but preparations should not be postponed: the classification for 2027 will already be determined by the 2025 financial statements, and the notification deadline is 20 February 2027.
According to the explanatory memorandum, the purpose of the separate tax base calculation is to align the tax base of large companies with the rules of the global minimum tax (Pillar Two). However, the new regime uses a threshold of EUR 500 million, lower than the EUR 750 million Pillar Two threshold, and therefore also affects groups of companies that fall outside the scope of the global minimum tax. In this newsletter, we present the large company rules in detail and also discuss how they affect the corporate income tax group decisions to be made by 20 November.
According to the explanatory memorandum, the purpose of the separate tax base calculation is to align the tax base of large companies with the rules of the global minimum tax (Pillar Two). However, the new regime uses a threshold of EUR 500 million, lower than the EUR 750 million Pillar Two threshold, and therefore also affects groups of companies that fall outside the scope of the global minimum tax. In this newsletter, we present the large company rules in detail and also discuss how they affect the corporate income tax group decisions to be made by 20 November.
Wealth tax and exit tax: legislation nearing completion
On 27 October 2026, the Government submitted the wealth tax bill (Bill No. T/930) to Parliament. The same day, it submitted a tax package (Bill No. T/927) that, among others, introduces new exit tax rules in personal income tax. Parliament may still amend both proposals, but with their submission the rules have taken near-final shape.
Attention: Important deadline! Corporate income tax group election will be open between 1 and 20 November
Qualifying company groups may apply to the Hungarian Tax Authority (NAV) for corporate income tax group status for the 2027 business year during the application period running from 1 to 20 November 2026. Applications to join an existing corporate income tax group may also be submitted during this application period. Companies that miss the above deadline will have to wait a whole business year for another opportunity.
Wealth tax: the HUF 1 billion threshold may be closer than many think
In line with the Government’s earlier decision, the draft Act on Wealth Tax (“draft legislation”) was released for public consultation on 6 October 2026. As per the draft legislation, the Act is scheduled to enter into force on 15 December 2026. If adopted in its current form, affected taxpayers would be required to fulfil their first wealth tax obligations by 31 August 2027, based on their wealth as of 31 December 2026.
Ministry of Finance Guidance on the New Transfer Pricing Documentation Decree
We are living in times of significant changes in the Hungarian transfer pricing regulatory environment. In December 2025, the new transfer pricing documentation decree (Decree No. 45/2025 of the Ministry for National Economy) was published, fundamentally transforming the rules of documenting and disclosing transactions between associated enterprises.
PPWR: Application of the new rules has begun
As of 12 August 2026, the European Union's new Packaging and Packaging Waste Regulation (PPWR) has become applicable. The good news is that businesses are not required to comply with all new requirements overnight. The European Commission envisages a gradual implementation and has indicated that, during the initial period, market surveillance authorities will focus primarily on facilitating compliance rather than strict enforcement.
Nevertheless, companies should not postpone their preparations. It is also important to emphasize that existing Hungarian obligations, particularly the extended producer responsibility (EPR) scheme and the mandatory deposit return system (DRS), remain in force even after the PPWR has entered into application.
Nevertheless, companies should not postpone their preparations. It is also important to emphasize that existing Hungarian obligations, particularly the extended producer responsibility (EPR) scheme and the mandatory deposit return system (DRS), remain in force even after the PPWR has entered into application.
A turn regarding the M sheet: the new completion rules do not have to be applied after all
In our newsletter published a few weeks ago, we presented in detail the stricter completion rules for the domestic recapitulative statement - commonly known as the M sheet - entering into force as of 1 July 2026. Since then, however, a significant turn has taken place: the legislator has initiated the withdrawal of these amendments, therefore the previous rules will evidently remain applicable.
The most important changes in the summer tax package
Hungary must implement several tax-related commitments related to the Recovery and Resilience Facility (RRF) by 31 August 2026: the personal income tax exemption for trusts will be abolished; the number of corporate income tax incentives will be reduced in order to increase tax revenues; the competitive conditions for the retail tax will be harmonised; and the number of tax types will be reduced. In order to fulfil these commitments, Bill No. T/387 (the “Proposal”) has been submitted. We summarize its most important tax provisions below.
Changes to and Extension of the Crude Oil Industry Windfall Tax
Act XXXII of 2026, adopted on 14 July 2026 and promulgated in issue no. 91 of the Hungarian Gazette (Magyar Közlöny) on 18 July 2026, amends the rules of the special tax payable by crude oil product manufacturers: it converts the tax built on the price differential between Brent and Russian crude oil into a tiered rate structure and extends it to the tax year beginning in 2027. The amendment to Act LIV of 2025 on certain tax obligations and the amendment of certain tax acts (hereinafter: the “Windfall Tax Act”) also makes part of the previously exempt price-differential range taxable. The new rules must first be applied to the monthly tax liability for August 2026.
New M sheet rules to enter into force as of 1 July 2026
1 July 2026 is a date that all Hungarian VAT taxpayers should mark in their calendars. On this date, the amendment to the “Receipt of invoices” section of Annex 10 to Act CXXVII of 2007 on Value Added Tax (hereinafter: “VAT Act”) will enter into force. The new rules will substantially reshape the completion of the domestic recapitulative statement, commonly referred to as the M Sheet, while the Hungarian Tax Authority’s long-standing objective remains that, from 1 January 2027, VAT returns should be submitted exclusively via the eVAT platform, either through the web interface or via an M2M connection.
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