In November 2025, the Hungarian Parliament adopted two closely related tax packages:
- The first is Act LXXXIII of 2025 on amendments to certain tax laws aimed at reducing administrative burdens and ensuring legal harmonisation (the “first tax package”),
- The second is Act LXXXIV of 2025 on measures to reduce the tax burden of businesses (the “second tax package”).
The first tax package mainly contains legal harmonisation and technical amendments, as well as measures to reduce administrative burdens (e.g. VAT group rules, global minimum tax, clarifications to tax administration and accounting rules). The second tax package introduces real, substantial tax cuts and administrative simplifications—primarily for SMEs, KIVA taxpayers, sole entrepreneurs, retailers, and energy service providers.
Below we summarise the key changes by thematic area. This summary is not exhaustive; specific transactions or business decisions require an assessment of the individual facts and circumstances.
I. Personal Income Tax – Crypto, Family Benefits, Lump-Sum Taxpayers
1. Crypto Transactions – unlimited loss offset
A major simplification in the first tax package is the removal of the previous two-year time limit for loss offset related to crypto transactions.
- Currently, individuals may offset their annual crypto gains only with results from the preceding two tax years.
- Under the new rules, losses realised in any prior year may be offset—without a time limit—against future gains, provided these losses were previously declared.
A key administrative requirement is that individuals must maintain records showing the amount of unused losses eligible for tax offset, and must include this information in their tax return.
The amendment may already be applied in the tax return for 2025.
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2. Tax Relief for Mothers with Multiple Children – simplified withholding declaration
Administrative simplifications accompany the lifelong PIT exemption gradually introduced for mothers with two or three children:
- From 2026, eligible mothers may indicate their entitlement directly on the standard family allowance declaration.
- “Continuing” withholding declarations will be allowed: employers/payers may treat a declaration submitted in 2025 as valid until a new one is submitted.
This means eligible mothers will no longer need to file a new declaration each year.
3. Food Purchases allowed with SZÉP Card
On a temporary basis, between 1 December 2025 and 30 April 2026, SZÉP Card balances may also be used for food purchases at the following types of retailers:
- mixed food retail,
- fruit and vegetable shops,
- meat and meat product shops,
- fish shops,
- bakery and confectionery retail,
- other food retail.
4. Lump-Sum Taxpayers – increased cost ratio
The second tax package increases the deductible cost ratio for lump-sum (átalányadózó) sole entrepreneurs subject to the currently applicable 40% rate (typically service providers):
- to 45% from 2026,
- to 50% from 2027.
This results in a higher deemed cost portion and lower taxable income, reducing PIT and expanding the contribution-exempt income portion.
5. Tax exemption for Bank Compensation due to phishing fraud
A new rule affecting a broad range of individuals provides that compensation voluntarily and on an equitable basis paid by a bank to a customer who fell victim to phishing is treated as tax-exempt income.
- The exemption applies up to the amount of the actual loss.
- Any compensation exceeding the actual loss is taxable under the general rules.
The amendment applies from 20 November 2025.
II. Social Security, Social Contribution Tax (Szocho), Sole Entrepreneurs
1. “Long-Term Commissioned Status” – A New Insured Status
The first tax package introduces a new form of insured status: the “long-term commissioned legal relationship”.
- A commission agreement qualifies as long-term if the parties report it to the tax authority.
- Insurance obligations arise regardless of remuneration amount; contributions and Szocho are payable on the actual fee, but at least 30% of the minimum wage.
- The insured status and contribution payments continue until the principal reports the termination.
The aim is twofold:
1) to reduce retrospective, back-dated reporting, and
2) to improve access to benefits (e.g. sick pay) for contractors.
Effective from 1 January 2026.
2. Full-Time Sole and Corporate Entrepreneurs – lower minimum Szocho base
The second tax package lowers the minimum Szocho base for full-time sole and corporate entrepreneurs:
- from 112.5% of the minimum wage to
- 100% of the minimum wage from 2026.
This reduces the compulsory contribution burden for entrepreneurs who pay contributions on the minimum base.
3. Quarterly reporting of Social Security Contributions for sole entrepreneurs
From 2026, sole entrepreneurs taxed under the entrepreneurial income method:
- will determine and pay social security contributions and Szocho quarterly,
- and will report them monthly within the quarterly return—similar to lump-sum taxpayers.
This offers liquidity and administrative benefits to tens of thousands of entrepreneurs.
4. Unified Social Security Information Platform
The first tax package provides for the creation of a comprehensive system allowing individuals to access their:
- pension-related contributions,
- health insurance benefit data,
- health service contribution information
on a single platform.
This simplifies administration and helps with planning and verifying contribution payments.
See what tax opportunities the autumn package opens up for your company.
III. Value Added Tax
1. VAT Groups – Simplified Formation, Stricter Liability
Key amendments to VAT group rules include:
- Simplified formation: it will be sufficient for members to declare that their systems can distinguish intra-group and external transactions; detailed documentation will no longer be required.
- Group representative termination: if the representative’s status ceases, members must appoint a new representative within 15 days. Failing this, the tax authority designates the member with the highest tax performance. The group will no longer automatically terminate in such cases.
- Extended joint and several liability: group members will now also be jointly and severally liable for sanctions under the Tax Administration Act (Art.), not only for VAT obligations.
Effective from 20 December 2025.
2. New data reporting in VAT returns – Deducted VAT at invoice level
From 1 July 2026, a new data field will be added to the domestic recapitulative statement (M sheets):
- in addition to the taxable amount and VAT charged, the deductible VAT per invoice must also be declared;
- the requirement applies to adjustment, cancellation, and advance-payment invoices (K sheets);
- only taxpayers using the eVAT system are exempt.
The rule applies from the tax period covering 1 July 2026. Businesses must prepare their invoicing and accounting systems in time.
3. Small Taxpayer Exemption – Threshold increasing to HUF 24 Million
The second tax package raises the VAT small-taxpayer (alanyi mentesség) threshold as follows:
- 2024–2025: HUF 18 million
- 2026: HUF 20 million
- 2027: HUF 22 million
- 2028: HUF 24 million
This is significant for micro-enterprises and sole entrepreneurs, allowing VAT-exempt operation up to higher turnover levels.
4. VAT on Beef reduced to 5%
From 1 January 2026, the VAT rate is reduced from 27% to 5% for meat, slaughter by-products, and offal of domesticated cattle intended for consumption.
5. VAT Refund for Foreign Travellers – formal clarifications
The first tax package clarifies the formal requirements (documents, certifications) for VAT refunds to foreign travellers. The changes apply from 20 November 2025, with further details to be set out in implementing regulations.
Discover what new liquidity benefits the tax package could create for your company.
IV. Corporate Income Tax and Global Minimum Tax
1. R&D Tax Credit – Lower Cap, More Flexible Reversion
Rules for the global-minimum-tax-compatible R&D tax credit introduced last year are amended in two ways:
- For projects undertaken with universities, the Academy of Sciences, or research institutes, the credit cap—previously 100% of costs—is adjusted to activity-specific aid intensities, while retaining the annual limit of HUF 500 million.
- From 20 December 2025, the new intensities are:
- basic research: 100%,
- applied (industrial) research: 50%,
- experimental development: 25%.
- Taxpayers may revert to the “traditional” corporate tax deduction after 5 years (instead of the current 6).
This allows companies to revisit their R&D strategies earlier in light of both global minimum tax and Hungarian CIT incentives.
2. New Investment Tax Credit for “clean technologies”
The second tax package introduces a new CIT tax credit for investments creating or expanding manufacturing capacity for clean technologies.
- Maximum aid intensity: 15% in Budapest, 35% outside Budapest.
- The investment is eligible only if, without aid, it would be carried out outside the EEA.
- Transitional rules allow certain projects previously notified under another investment tax credit to transfer to this category.
The existing “net-zero strategic investment” credit is discontinued, as the EU crisis framework expires in 2026.
3. New Environmental Investment Tax Credit
A new CIT credit applies to investments and refurbishments aimed at eliminating environmental damage or achieving other ecological objectives:
- Available for projects with a present value of at least HUF 100 million.
- For remediation of environmental damage: 100% of eligible costs.
- For other ecological investments: 70% of eligible costs, plus an additional 20 percentage points for small and 10 points for medium-sized enterprises.
- Maximum benefit: EUR 30 million present value.
- The credit may reduce CIT liability by up to 70%.
- Prior notification to the Ministry of National Economy is required before the start of the planned investment; NAV audit is mandatory within three years of claiming the credit.
First applicable in tax year 2026 and for investments starting after 1 January 2026.
4. Corporate Income Tax advance payment frequency
- From 1 January 2026, the threshold for quarterly CIT advance payments increases from HUF 5 million to HUF 20 million of prior-year CIT payable. Only taxpayers exceeding this amount must pay advances monthly.
- The new rule applies for returns submitted after 31 December 2025 based on 2025 CIT liability.
- The deadline for the final quarterly advance is moved forward to the 20th day of the last month of the quarter.
5. Global Minimum Tax – New Safe Harbour Definitions
Amendments to the supplementary tax law ensuring the global minimum tax include:
- the introduction of simplified covered taxes, simplified effective tax rate, qualified country-by-country report, and qualified financial statements as statutory definitions;
- clarification of percentage values to be used when applying the substance-based income exclusion (e.g. 9.6% for payroll and 7.6% for tangible assets for tax years starting in 2025).
This enhances legal certainty for multinational groups applying Safe Harbour rules.
V. Small Business Tax (KIVA)
1. Electronic Money Excluded from KIVA “Cash” Value
Under the first tax package, electronic money is removed from the definition of “cash” under the KIVA rules.
From 2026, changes in electronic money must be disregarded when calculating the annual change in cash that adjusts the tax base.
2. Full-Time Corporate Entrepreneurs’ Remuneration
From 1 January 2026, remuneration attributable to full-time corporate entrepreneurs must equal at least 100% of the guaranteed wage minimum (currently 112.5%).
3. Higher Entry and Exit Thresholds for KIVA
The second tax package significantly broadens KIVA eligibility:
- Entry thresholds:
- maximum average statistical headcount: 50 → 100
- revenue and balance sheet total: HUF 3 billion → HUF 6 billion
- new thresholds may be applied from 1 December 2025.
- Exit thresholds from 2026:
- revenue limit: HUF 6 billion → HUF 12 billion
- headcount limit: 100 → 200
As a result, many medium-sized enterprises may also consider switching from CIT to KIVA.
VI. Duties (Illeték)
1. Waiver of Loan in Liquidation – General Duty Exemption
If, during liquidation, a shareholder waives a receivable against the company, the acquisition is exempt from duty,
- provided that the liquidation ends with the company’s deletion from the register.
- If not, the suspended duty must be paid with late-payment interest.
Effective from 1 January 2026.
2. “Leaseholder’s Right” in the Duties Act
The concept of “leaseholder’s right”, introduced in real estate registration law from 2025, is now incorporated into the Duties Act as well—e.g. in relation to the reduced duty rates for properties purchased for resale.
Effective from 1 January 2026; particularly relevant for real-estate transactions involving financial leasing.
VII. Special Taxes, Advertising Tax, Excise Duty
1. The returning of Advertising Tax from 1 July 2026
The suspended advertising tax is extended only by half a year:
- Without another extension, the advertising tax will again become payable from 1 July 2026.
- Media and advertising market participants should plan ahead—especially regarding long-term contracts.
2. New Tax Credit for the “Robin Hood Tax” (Energy Providers’ Income Tax)
From 2026, a new investment tax credit can reduce the energy providers’ income tax (Robin Hood tax):
- The credit may be used in the year the energy-related investment is put into service and in the following five tax years, up to 80% of the tax payable.
- The amount is capped at 50% of the difference between eligible costs and adjusted depreciation (present value).
This supports financing large energy infrastructure investments.
3. Retail Sector Special Tax – higher brackets
The second tax package eases the brackets of the retail special tax, reducing the burden for many retailers:
- 0% rate up to HUF 1 billion (previously HUF 500 million),
- the 0.15% bracket upper limit: HUF 30 → 50 billion,
- the 1% bracket upper limit: HUF 100 → 150 billion,
- the top 4.5% rate applies only above HUF 150 billion.
Applicable already for the 2025 tax year. (Rules for fuel retailers remain unchanged.)
4. Excise Duty increase postponed
The automatic, inflation-based excise increase on petrol, paraffin, and diesel will take effect not on 1 January 2026 but on 1 July 2026.
5. Related but Separate Regulation: Increase of the Bank Special Tax
Government Decree 358/2025 (XII.13.) sets higher bank special tax rates to partly offset tax cuts in the autumn packages:
- in 2026, banks will pay 10% (instead of 8%) on the first HUF 20 billion of their tax base;
- and 30% (instead of 20%) above this amount;
- meanwhile, the government bond-related tax credit may reduce the tax only up to 30% (previously 50%).
Government estimates indicate revenue increasing from HUF 180 billion to HUF 360 billion, providing partial coverage for the business tax reductions.
Author:József Vizer, Lead Tax Advisor at ICT Business Advisory Zrt.
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