Act LIV of 2025 on Certain Tax Obligations and Amendments to Various Tax Laws has been officially published. Below, we summarize the most important changes in taxation and accounting.
I. Special Tax Liability of Credit Institutions and Financial Enterprises
The special tax rules for banks introduced during the state of emergency are being elevated to statutory level and extended to apply to the tax year starting in 2026 as well.
For the 2025 tax year, the basis of the special tax is the pre-tax profit calculated from the 2023 annual financial statements, adjusted by various increasing and decreasing items. The tax rate is 7% up to HUF 20 billion, and 18% on the portion exceeding that amount.
A tax credit may be claimed for government bond purchases: 10% of the increase in holdings, up to a maximum of 50% of the payable tax amount.
The tax must be paid in two equal installments: by June 10 and December 10.
In 2026, the tax base will be the pre-tax profit determined from the 2024 annual financial statements, adjusted by various modifying items. The tax rate will be 8% up to HUF 20 billion, and 20% on the portion exceeding that amount.
The tax credit for increases in government bond holdings will also apply for the 2026 tax year, provided that the volume of government bonds maturing after January 1, 2030, increases compared to the base periods. The credit applies only to government bonds denominated in Hungarian forints; retail government bonds are not eligible for the credit.
II. Special Tax Liability of Crude Oil Product Manufacturers
The Brent–Ural differential tax introduced under the state of emergency decree is being elevated to statutory level and extended to apply in 2026 as well.
The tax base is calculated as the product of the global market price differential for crude oil originating from the Russian Federation and the volume of crude oil—measured in barrels—purchased from the Russian Federation during the relevant month. A reduction of USD 5 per barrel may be applied to this amount.
The tax rate remains at 95%.
III. Income Tax of Energy Suppliers
The spring tax package elevates to statutory level the 41% income tax rate for energy suppliers applicable in 2025, while also confirming that the rate will return to the original 31% as of 2026.
IV. Insurance Tax
The spring tax package elevates the decree-based rules applicable for 2025 to statutory level and extends their application to 2026 as well.
Insurance tax allowances (with standard rates of 15% for casco insurance and 10% for property and accident insurance) will remain available if the tax base of the previous year did not exceed HUF 20 billion. Accordingly, the effective tax rates payable are as follows:
- Up to HUF 250 million: 25% of the standard tax rate
- Between HUF 250 million and HUF 1.75 billion: 50% of the standard tax rate
- Above HUF 1.75 billion: 100% of the standard tax rate
Supplementary Insurance Tax Rate for 2025–2026:
- For non-life insurance: 3% up to HUF 48 billion, 14% on the portion exceeding that amount
- For life insurance: 2% up to HUF 48 billion, 6% on the portion exceeding that amount
The rules on the government bond-related tax credit are also being elevated to statutory level and will remain applicable in 2026.
V. Retail Sector Special Tax
The spring tax package elevates the government decree-based rules on the retail sector tax applicable for 2025 to statutory level and extends their application to 2026 as well.
The retail tax rates, excluding retail activities related to motor vehicle fuel, are as follows:
a) 0% on the portion of the tax base not exceeding HUF 500 million,
b) 0.15% on the portion of the tax base exceeding HUF 500 million but not exceeding HUF 30 billion,
c) 1% on the portion of the tax base exceeding HUF 30 billion but not exceeding HUF 100 billion,
d) 4.5% on the portion of the tax base exceeding HUF 100 billion.
For retail trade in motor vehicle fuel, the applicable tax rates are as follows:
a) 0% on the portion of the annual net revenue from motor vehicle fuel retail that does not exceed HUF 500 million,
b) 3% on the portion of the annual net revenue from motor vehicle fuel retail that exceeds HUF 500 million.
VI. Personal Income Tax (PIT)
In our previous post we provided a detailed overview of the tax exemptions for infant care allowance, childcare allowance, and adoption allowance, as well as the lifetime personal income tax exemption for mothers with three or two children, and the exemption for mothers under the age of 30. With the introduction of these benefits, it has become necessary to establish the order in which the tax allowances are to be applied, with effective dates of July 1, 2025; October 1, 2025; and January 1, 2026.
a) the tax allowance for mothers under the age of 30,
b) the tax allowance for mothers raising four or more children, and for mothers raising three children,
c) their respective allowance, or the tax allowance for mothers raising two children,
d) the tax allowance for infant care allowance, childcare allowance, and adoption allowance,
e) the tax allowance for individuals under the age of 25,
f) personal allowance,
g) the allowance for first-time married couples,
h) family tax allowance.
Retirees claiming the child-related tax allowance are not required to file a personal income tax return, unless their income subject to the allowance is received from a non-payer (e.g., income from self-employed activity as a sole proprietor or agricultural producer) and their annual revenue exceeds four times the average wage.
A uniform 12% differential penalty rate will apply in cases where an incorrect tax advance declaration was made regarding itemized cost accounting, or where tax base allowances were claimed without legal entitlement in the personal income tax return. No penalty is imposed if the difference does not exceed HUF 10,000.
The microenterprise employer tax base allowance will increase from 100% to 150% and can be claimed based on headcount growth compared to the previous year and the applicable minimum wage. The headcount threshold will rise from 5 to 10 employees.
Under the current regulation, the private use of bicycles powered solely by human effort or assisted by an electric motor with a maximum output of 300 W qualifies as tax-exempt. In line with advancements in electric bicycle technology, the motor power limit will be increased from 300 W to 750 W as of January 1, 2026.
VII. Social Contribution Tax (SCT)
Unlike the general Szocho exemption for retirees receiving their own pension, if a retired individual claims personal income tax allowances based on the number of children and their annual income exceeds four times the average annual wage, the payer becomes subject to a social contribution tax obligation—provided that tax advance withholding would otherwise apply (e.g., for salary or service fees). For the purpose of calculating the income threshold, payments from related parties must be aggregated. The tax must be declared and paid by the payer in the January tax return of the following year.
VIII. Value Added Tax (VAT)
According to the spring tax package, in the case of product exports, data marked with a digital stamp—equivalent to customs endorsement and sealing—will also be accepted as proof of exit.
The provisions of the Government Decree raising the threshold for opting for VAT exemption to HUF 18 million will be elevated to statutory level.
As of January 1, 2025, domestic reverse charge VAT will apply to natural gas sales between taxable traders as defined by the VAT Act. In this context, the purchaser will be required to declare to the seller that they qualify as a taxable trader. A new provision will also impose data reporting obligations on both the seller and the purchaser, including details such as the quantity of gas.
The spring tax package reflects the amendment to the VAT Act, postponing the introduction of mandatory general receipt data reporting from the originally planned date of July 1, 2025, to September 1, 2026.
As of January 1, 2026, in the case of legal succession, if the successor issues an invoice for a transaction carried out by the predecessor, the online invoice data reporting must also include the tax number of the predecessor. In the case of invoicing by a group VAT taxpayer, the data report must also include the tax number of the specific group member issuing the invoice.
IX. Excise Duty
As of July 1, 2025, the spring tax package allows for the electronic recording of reports and notes related to on-site inspections conducted by the Hungarian Tax Authority (NAV) in excise duty matters.
Starting from the 31st day following the publication of the law, the threshold value of financial loss identified during excise inspections—up to which a fast-track procedure may still be applied—will be increased (from HUF 20,000 to HUF 80,000 in general cases, and from HUF 28,000 to HUF 98,000 for tobacco products). Additionally, instead of a fixed amount, a maximum penalty amount will be introduced.
X. Corporate Income Tax (CIT)
The microenterprise employer tax base allowance will increase from 100% to 150%. It can be applied to the increase in the average number of employees compared to the previous tax year, multiplied by the annualized amount of the monthly minimum wage in effect on the first day of the tax year. The associated headcount limit will rise from 5 to 10 employees. The new rules may already be applied for the 2025 tax year.
The HUF 50 million cap on the corporate tax base allowance for direct costs related to research and development activities carried out in cooperation with higher education institutions, the Hungarian Academy of Sciences, and certain other research institutions will be increased to HUF 150 million.
In the case of a preferential transfer of assets, if the holding requirement is only partially breached, the deferred tax liability will no longer be reversed in full. Instead, it will be reversed only in proportion to the non-compliant portion, based on the ownership share. Both the transferor and the transferee must apply this rule as of January 1, 2025.
The rules on reported participations will be extended to cover cross-border transformations. If a taxpayer becomes a Hungarian tax resident as a result of a cross-border transformation that took place in 2024, the provision may be applied, provided that the taxpayer reports to the tax authority—within 75 days of the rule’s entry into force—those participations acquired prior to obtaining Hungarian tax residency, as long as such participations have not yet been reported by the effective date of the provision. Failure to meet the deadline will result in forfeiture of the right to apply the allowance.
The power limit applicable to bicycles recognized as a corporate expense will be increased to 750 W. This change must already be taken into account for the 2025 tax year.
Parties involved in a demerger qualifying as a preferential transfer of assets are exempt from transfer pricing obligations.
XI. Small Business Tax
If, during a merger or demerger carried out at book value, the taxpayer opts to re-enter the Small Business Tax system, the rules on transitional differences do not need to be applied. This exception applies in cases of termination and re-entry occurring after the amendment enters into force.
XII. Global Minimum Tax
The deadline for reporting global minimum tax status to the tax authority will be extended from the last day of the tax year to the last day of the second month following the end of the tax year.
Due to the global minimum tax, the actual amount of top-up tax payable for a given financial year will only be available after the deadline for preparing and publishing the annual financial statements for that year (and will thus be reported retroactively). As a new accounting requirement, the expected amount of top-up tax attributable to the financial year in question must be recognized as a deferred liability for that same year. This deferred amount must then be reversed upon final determination of the tax amount and set off against the tax payment obligation. The new requirement applies to financial statements prepared for financial years starting in 2025.
It is introduced that a penalty of up to HUF 10 million may also be imposed for non-compliance with data reporting obligations. The transitional exemption applicable to tax years beginning before December 31, 2026, will extend to this legal consequence as well.
XIII. Local Taxes
The local business tax liability of gambling operators will be reduced, as from July 1, 2025, they may deduct the amount of accounted prize payouts from their net revenue when determining the tax base.
Effective the day after the law is promulgated, the tax exemption available to general practitioners and health visitor entrepreneurs may be claimed not only up to a local business tax base of HUF 20 million, but also up to HUF 40 million.
The spring tax package creates the legal basis for the Hungarian Tax Authority (NAV) to share certain data—crucial for local taxation purposes—via the ASP system operated by the Hungarian State Treasury. This includes the bank account information of taxpayers not required to register with the company court, as well as data related to taxpayers opting for KIVA status.
XIV. Company Car Tax
As of July 2025, company car tax exemption will also apply to passenger vehicles operated for the core activities of civil guard organizations supporting public duties and volunteer firefighter associations.
XV. Duties
Starting from the 31st day following the promulgation of the law—and also applicable to ongoing procedures—the portion of the market value of land properties corresponding to the value of structures used for solar or wind power plants will be exempt from the transfer duty on onerous property transfers.
XVI. Tax Procedure and Administration
The Hungarian Tax Authority (NAV) will be authorized to withhold budgetary support (refunds or reimbursements) due to a taxpayer after their termination without legal succession, up to the amount of any outstanding debts owed by the rightful claimant of the refund or reimbursement.
Currently, payment service providers must report the opening and closing of payment accounts to the Hungarian Tax Authority (NAV) within 15 days. This deadline will be reduced to 7 days.
The tax authority may record minutes of on-site inspections electronically. If the person participating in the procedure does not have an electronic signature, the minutes shall be signed using a biometric signature.
The spring tax package ensures that members or shareholders of a company—who are not executive officers—may access information regarding the amount of the company's tax debt classified as tax secret, for the purpose of settling the debt, if the person(s) authorized to act on behalf of the company fail to do so and the members or shareholders wish to pay the debt to enable continued operation. In the case of publicly listed companies, shareholders will still not be entitled to access such tax information.
Taxpayers will have the option to initiate a preliminary consultation electronically before submitting a request for an advance tax ruling. The fee for this consultation is HUF 1 million.
A taxpayer may request removal from the public list of undeclared employees once per calendar year, provided that the failure to report involves no more than five individuals and the penalty triggering the publication is paid by the due date.
As a result of the amendments, the threshold amount for which the tax authority may automatically grant installment payment—once per year and without examining further conditions—will increase from HUF 1 million to HUF 2 million (up to 12 months for individuals, and up to 6 months for non-individuals). For reliable taxpayers, this threshold will increase from HUF 3 million to HUF 5 million.
The fee for procedures aimed at determining the arm’s length price will increase from HUF 8 million to HUF 10 million for unilateral procedures, and from HUF 12 million to HUF 14 million for bilateral or multilateral procedures, effective from the 31st day following the promulgation of the law. Additionally, the fee for preliminary consultations will increase from HUF 500,000 to HUF 1 million per consultation.
XVII. Accounting
Under the current regulations, parent companies are always subject to statutory audit requirements, even if they do not prepare consolidated annual financial statements. According to the spring tax package, parent companies exempt from the obligation to prepare consolidated financial statements may also be exempt from statutory audit, under the same conditions as other companies. This amendment will first apply to financial statements prepared for business years starting in 2026.
In connection with the entry into force of sustainability reporting requirements, the spring tax package amends the Accounting Act to reflect the directive published by the European Union in April 2025, which postpones compliance for certain companies by two years.
It has been clarified that the ESEF format applies exclusively to the preparation of the sustainability report and does not need to be used for the auditor’s assurance opinion.
This blog post was written by József Vizer, Managing Director at ICT Business Advisory Zrt.
