On 17 July 2026, Bill No. T/387 (hereinafter: the "Tax Package") was submitted to the Hungarian Parliament. In addition to tax measures related to the implementation of the Recovery and Resilience Plan, the Bill would also revise several tax rules that have already entered into force.
According to the explanatory memorandum to the Tax Package, Hungary undertook, among other things, to reform the taxation of trust asset management arrangements (Hungarian abbreviation: BVK) and private foundations, reduce the number of corporate income tax (CIT) incentives, level the competitive conditions under the retail tax, and reduce the number of tax categories by 31 August 2026.
The most significant changes would affect BVKs and private foundations, certain CIT incentives, the retail tax, environmental load charges and the carbon dioxide quota tax. The summary below presents the key provisions of the Bill as submitted. The detailed rules and effective dates may still change during the parliamentary procedure.
I. What changes could the 2026 summer tax package bring for trust asset management arrangements and private foundations?
1. New record-keeping obligations could apply to assets transferred to BVKs
Under the proposal, the transfer of an asset to a BVK or into the ownership of a private foundation would, as a general rule, continue not to give rise to an immediate tax liability. continue not to give rise to an immediate tax liability..
Subject to the exceptions specified by law, however, an unrealised increase in asset value would have to be determined for transferred assets. increase in asset value This would essentially be the difference between the value recognised in the transferee's books and the transferor's documented acquisition cost and other deductible costs. The basic rules in this area remain unchanged
- Two-step register: A detailed primary register would have to be maintained for the increase in asset value of each asset. If a transferred asset is subsequently sold, the related increase would have to be transferred to a separate register.
- Strict proof requirement if documentation supporting the acquisition is unavailable, the asset's full carrying amount would have to be treated as an increase in asset value.
- 15-day deadline: The trustee would have to inform the settlor of the carrying amount and the determined increase within 15 days.
The real novelty of the T/387 proposal covers crypto assets (for which no increase in asset value can be determined) and the rules for the entry of shares acquired under a beneficial share exchange.
2. Tax-exempt asset distributions could remain available, but the acquisition cost rules would change
If the beneficiary receives exactly the same asset that the settlor previously transferred into trust asset management, a distribution charged to the initial capital could continue to be tax-exempt. For assets transferred on or after 31 August 2026 the tax-exempt distribution of the same asset would not be subject to a five-year waiting period. As a general rule, however, the beneficiary's acquisition cost would not be the market value at the time of distribution, but the documented amount spent by the settlor on acquiring the asset. This means that, although the asset distribution could be tax-exempt, theincrease in value accumulated before the asset was placed into trust could be reflected in the beneficiary's taxable income upon a subsequent disposal.
3. Stricter taxation could apply to asset distributions made in cash or in another form
The most important change concerns the distribution of assets in a different form. For example, the settlor may have transferred ownership interests into trust asset management, the trustee may have sold them, and the beneficiary may subsequently receive cash, other securities or another asset.
In such cases, the proposal would introduce an ordering rule:
- first, the distribution would be presumed to be made from the accounting profit and reserves of the managed assets and would be taxed as a dividend;
- next, a distribution charged against the increase in asset value recorded in the separate register would also qualify as a dividend;
- only the remaining capital portion, essentially corresponding to the historical acquisition cost, could be distributed tax-free.
In practice, this could significantly restrict the previously favourable option whereby an asset was transferred into trust asset management at a higher value and, following its sale, the revalued capital was paid out in cash on a tax-free basis.
The new provisions are intended to enter into force on 31 August 2026. It is important, however, that the new tax exemption rules could also apply to subsequent asset distributions where the asset had already formed part of the managed assets before that date. At the same time, certain existing transitional rules - including provisions relating to certain trust asset management arrangements established before 12 September 2023 and to assets that had already been revalued - would remain in force. Existing structures would therefore need to be assessed on a case-by-case basis
4. The transfer of crypto-assets to a BVK could constitute a separate taxable event
From 31 August 2026, the transfer of a crypto-asset into trust asset management or into the ownership of a private foundation would qualify as a transaction involving a crypto-asset. The amount at which the managed assets or private foundation recognise the crypto-asset in their accounting records would have to be treated as income.
This means that, unlike the transfer of other assets, the transfer of a crypto-asset could already generate taxable transaction income for the settlor and, depending on the settlor's other crypto-asset transactions in the relevant tax year, an actual tax liability. This is because the transfer into trust itself would qualify as a transaction involving a crypto-asset, and the increase in value accumulated up to that point could therefore be realised for tax purposes when the crypto-asset is transferred to the BVK or private foundation. As a result, the tax deferral that would generally remain available upon the transfer of other assets would not apply to crypto-assets, which could substantially reduce the tax attractiveness of such transfers.
No increase in asset value would have to be determined upon the transfer of a crypto-asset. If the crypto-asset is subsequently distributed in unchanged form, the beneficiary's acquisition cost would be the crypto-asset's accounting acquisition cost.
5. The taxation of the free or discounted use of managed assets would be restructured
Under the current rules, the value obtained by a beneficiary through the use of an asset forming part of the managed assets or owned by a private foundation, without acquiring ownership of that asset, is generally tax-exempt. However, the costs and expenses connected with such use and borne by the managed assets or the private foundation's assets are already subject to public charges under the current rules.
From 31 August 2026, the Bill would not newly subject free or discounted use to tax, but would restructure its tax treatment. As a general rule, the costs and expenses associated with the free or discounted use of real estate, a motor vehicle or another asset forming part of the managed assets, without a transfer of ownership, would qualify as a certain specified benefit.
According to the explanatory memorandum, 15% personal income tax and 13% social contribution tax would be payable on 1.18 times the costs and expenses borne by the managed assets or the private foundation's assets. This would result in an effective burden of 33.04% of the relevant costs or expenses.
No such tax liability would arise if the beneficiary would not be liable to pay gift duty upon a transfer of ownership of the asset. In that case, no tax or contribution would be payable on the related costs and expenses as a certain specified benefit, and the value obtained through the use of the asset would also be tax-exempt for the beneficiary. This could be relevant, for example, where use is granted to a lineal relative, spouse or sibling.
The exemption would not apply if the individual acquired beneficiary status in consideration for, or in connection with, the performance of an activity, the transfer of property or the provision of a service.
6. New data reporting obligations and broader NAV audit powers could be introduced
The trustee and the private foundation would be required to report annually, among other things, the following data:
- the carrying amount of the managed assets,
- the carrying amount of each individual asset,
- the increases in asset value,
- and the year-end balance of the separate register.
The first data report, covering 2026, would have to be submitted by 31 March 2027. Subsequent reports would generally be due by 31 January of the year following the reporting year.
If the Hungarian Tax and Customs Administration (NAV) establishes a tax debt in respect of the managed assets and the debt cannot be recovered from those assets, NAV could require a person who received a benefit from the managed assets free of charge or on preferential terms to pay the tax debt up to the value of the income received.
Under the proposal, NAV would:
- audit assets managed by trustees registered before 12 September 2023 and private foundations;
- examine the circumstances of the settlement of assets, relationships with the advisers and lawyers involved, the content of the relevant agreements and the timing of asset distributions;
- and, from 1 January 2028, conduct audits of all BVKs and private foundations within the applicable limitation period.
7. More favourable rules could apply to TBSZ arrangements and transfers of assets upon death
A change in the identity of the trustee would not automatically interrupt a long-term investment contract (Hungarian abbreviation: TBSZ), provided that the new trustee enters into a TBSZ of the same type within 30 days and all assets recorded under the previous contract are transferred in full to the new contract.
Another favourable rule would provide that, where the trustee or private foundation acquires the assets upon the settlor's death, no increase in asset value would have to be determined. Furthermore, where the beneficiary acquires the assets following the settlor's death, the distribution could be tax-exempt and the acquisition cost would be the fair market value at the time of acquisition.
Could your trust structure be affected?
The proposed amendments may affect existing asset management arrangements in a number of ways. It is worth reviewing their tax and legal implications before they come into force.
II. Which corporate income tax changes could affect businesses?
1. CIT incentives relating to historic monuments could be phased out
From 1 January 2027, the corporate income tax base reductions relating to historic monuments and listed properties would be phased out. This would affect, among other things, the maintenance, investment and renovation of historic monuments, as well as the transfer of such an incentive to a related enterprise.
The incentives could be applied for the last time in the tax year beginning in 2026. Any previously acquired but unused incentive balance could not be carried forward beyond the 2026 tax year.
2. The option to elect the growth tax credit could be abolished
The proposal would repeal the rules governing the growth tax credit. The scheme currently allows taxpayers to pay the corporate income tax attributable to an exceptional increase in profit in several instalments.
Growth tax credits arising in 2026 or earlier would continue to be settled in accordance with the rules in force on 31 December 2026. However, the investment allowance could only reduce a tax instalment due before 1 January 2027.
3. The CIT rules governing support for universities and research organisations could change
The proposal would amend the CIT treatment of support in several respects:
- the book value of support, benefits, assets transferred without a repayment obligation to HUN-REN, the cost of services provided without a refund, and the VAT accounted for in connection with these would qualify as costs and expenses incurred in the interest of entrepreneurial activity;
- support provided to HUN-REN would generally entitle the taxpayer to a tax base reduction equal to 20% of the support, or 40% in the case of a long-term donation agreement;
- a 300% incentive would remain available for support provided to a church-maintained university or its maintaining body;
- several elements of the special CIT incentives and status rules relating to public interest asset management foundations performing public duties (KEKVAs) would be abolished and the exemption from the tax base increase item related to such supports would also be eliminated in the income tax of energy suppliers.
The 50% tax base discount related to the support %-of other higher education institutions operating under non-church maintenance would also cease as of August 1, 2027.
The current 300% tax base reduction relating to support for a KEKVA-maintained university or its maintaining body could continue to be claimed, on a transitional basis. The discount could be used for the last time in the tax year beginning in 2027. The related legal provisions would enter into force on August 1, 2027, but the transitional rule would allow the previous discount to be applied for the entire tax year starting in 2027.
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III. What VAT changes does the summer tax package contain?
1. Reporting on received invoices would not change after all
The proposal would effectively reverse, through a retroactive transitional rule, the more detailed reporting requirement for received invoices that entered into force on 1 July 2026. It would allow the rules in force on 30 June 2026 to be applied to the tax assessment period that includes 1 July 2026.
IV. What changes can be expected in the retail tax and sector-specific charges?
1. The special aggregation of the retail tax bases of related enterprises could be abolished
Under the current rule, the retail sales revenue of certain related enterprises must be aggregated. This applies in particular where the related-party relationship arose as a result of a demerger or spin-off after 14 April 2020, or where assets required for the retail activity were transferred or made available for use to another related enterprise after that date. As a result of the aggregation, the progressive tax rates must be applied to the group's combined revenue
The Tax Package would repeal the entire tax base aggregation rule and expressly provide that it would not have to be applied for the tax year beginning in 2026 either.
2. The carbon dioxide quota tax could be abolished retroactively
The proposal would abolish the carbon dioxide quota tax retroactively from its introduction, with effect from 7 October 2023.
NAV would refund, upon the taxpayer's application, the tax paid from 7 October 2023 and the related interest calculated in accordance with the Act on the Rules of Taxation. The application would have to be submitted within a 90-day forfeiture period following the entry into force of the provision.
A condition of the refund would be that the taxpayer has not pursued the same claim by another means, such as in court proceedings or another legal remedy procedure. In addition to the carbon dioxide quota tax, the proposal would also repeal the rules governing the related transaction fee.
3. Air pollution charge unit rates could double
From 1 October 2026, the unit rates applicable to emissions of sulphur dioxide, nitrogen oxides and non-toxic particulate matter would double::
- for sulphur dioxide, from HUF 50/kg to HUF 100/kg,
- for nitrogen oxides, from HUF 120/kg to HUF 240/kg,
- and for non-toxic particulate matter, from HUF 30/kg to HUF 60/kg.
The advance payment for the fourth quarter of 2026 would equal 50% of the actual annual charge for 2025. In 2027, each quarterly advance payment would equal 50% of the actual annual charge for 2026.
V. Which local tax changes should businesses prepare for?
1. The tourism tax exemption for refugees from Ukraine could be enacted at statutory level
An individual who arrived from Ukraine on or after 24 February 2022 and was lawfully present in Ukraine before arriving in Hungary would be exempt from tourism tax liabilities arising on or after 14 May 2026.
The provision would elevate the previous emergency regulation to statutory level.
2. The administration of local business tax advances could become simpler in the event of a separation
The proposal would simplify the rules for filing and paying local business tax (LBT) advances related to spin-offs under the Civil Code. The provisions would apply to tax liabilities arising from 14 May 2026 .
In the case of a separation under the Hungarian Civil Code:
- the predecessor could also fulfil the successor's tax advance reporting obligation until the 15th day before the next tax advance payment is due, and the legal predecessor could also make the report on his behalf;
- the predecessor could declare the expected LBT for the current year within 30 days of the separation;
- the municipal tax authority would adjust the advance instalments on the basis of that declaration;
- the legal predecessor could provide in the current year that the payment in excess of the amount of the payment obligation due on its tax account be transferred to the tax account of the legal successor. The transferred amount should be considered a payment made by the legal successor.
3. Three minor tax categories could also be abolished from 2027
With effect from 1 January 2027, the Tax Package would abolish:
- the municipal tax that local authorities may introduce,
- the dog control contribution,
- and the special immigration tax.
VI. What customs changes can be expected?
1. An electronic notification may replace a formal customs decision
Where an individual who is not a taxable person for VAT purposes submits a customs declaration in their own name and the customs authority conducts the procedure in accordance with the information contained in the declaration, no separate decision would need to be issued on the customs duty and import VAT payable. Instead, the information specified in the Tax Package would be communicated by electronic notification.
2. Certain small-value customs reliefs may be abolished
The Tax Package would align the Hungarian rules with the abolition at EU level of the customs duty exemption based on a low-value threshold. In the procedures concerned, customs duty may in future become payable in addition to import VAT. The relief under which amounts of customs duty and VAT below EUR 10 did not have to be paid or refunded in certain cases would also be abolished
VII. The international rules on the global minimum tax could also change
The top-up tax ensuring the global minimum level of taxation (GloBE) would be added to the taxes covered by the Convention on Mutual Administrative Assistance in Tax Matters. The amendment would primarily establish the legal basis for cross-border tax cooperation and the exchange of information; it would not, in itself, change the fundamental rules for calculating the top-up tax.
The rule would enter into force on the first day of the month following the expiration of three months from the date of receipt of the notification by the depositary. The exact date would be determined by a statement by the Minister of Foreign Affairs.
Summary: which changes should businesses start preparing for now?
The Tax Package contains measures that would increase tax burdens, reduce taxes and ease administrative obligations. The new rules relating to BVKs are among the most complex changes and would require the greatest preparation, while the abolition of the retail tax aggregation rule and the refund of the carbon dioxide quota tax could provide significant relief for the taxpayers concerned.
Make sure you’re prepared in good time for the 2026 tax changes!
Our tax and legal experts can help you understand the changes and determine the necessary steps.
This article was peer-reviewed by:
József Vizer
Senior Tax Adviser, Partner
ICT Business Advisory
Tamás Mendöl
Senior Tax Adviser
ICT Business Advisory
Dr. Zsidi Roland, LL.M.,
Lead Attorney, Partner
ICT LEGAL Termel & Zsidi Ügyvédi Iroda
Legal disclaimer:
This summary has been prepared on the basis of the Bill as submitted. It is intended solely for general information purposes and does not constitute tax or legal advice. The content of the Bill, its effective date and the transitional provisions may change during the parliamentary procedure. The assessment of any specific transaction or existing structure requires an individual review in every case.
A gyakorlatban bevált és adatvédelmi szempontból is megfelelő megoldás, ha a munkáltató a halotti anyakönyvi kivonatot kizárólag bemutatásra kéri be, a munkavállalót pedig nyilatkoztatja arról, hogy az elhunyt milyen rokoni kapcsolatban állt vele.
