Hungary: Autumn tax package adopted, including changes to global minimum tax rules

The National Assembly adopted two bills as part of the Autumn tax package: 

• The bill on the Amendment of Certain Tax Laws to Reduce Administration and for the Purpose of Legal Harmonization, published in the Hungarian Gazette on November 19, 2025
• The bill on Measures to Reduce the Tax Burdens of Businesses, published on November 21, 2025

The two bills include the following tax-related provisions:

Corporate income tax

The rules for selecting research and development (R&D) tax incentives are clarified. After opting for the new type of R&D tax allowance, taxpayers may now reconsider their choice after five years rather than six. They may decide either to continue with the new incentive or revert to the previous one, which is not recognized for global minimum tax purposes. This adjustment reflects the existing rule that the election is valid for five years.

Global minimum tax

Concepts related to the simplified effective tax rate (ETR) are defined in line with OECD guidelines. However, the detailed rules for the calculation will be set out in a ministerial decree, of which only the draft version—submitted for public consultation—is available.

Additionally, the Annex concerning transitional relief for the substance-based income exclusion will be amended to align with the percentages set out in the original OECD model rules. Substance-based income exclusion may be calculated using slightly lower rates than those currently in force for recognized payroll costs of eligible employees and for the book value of eligible tangible assets. For example, for 2024 the rates will be 9.8% and 7.8%, instead of the present 10% and 8%.

Value added tax (VAT)

The provisions on VAT group representation are amended, and the rules on the joint and several liability of VAT group members are further clarified.

As of January 1, 2026, the sale of beef and related offal will be subject to the reduced 5% VAT rate.

Excise tax

The 2026 valorization of the excise tax rate on fuels will be postponed for six months.

Income tax on energy suppliers

From January 1, 2026, distribution license holders under the Act on Electric Energy will be eligible for tax allowance on energy development investments commissioned during the tax year. The allowance may be claimed in the tax year the investment is commissioned, as well as the five following tax years. The tax allowance reduces the income tax liability of energy suppliers but may be claimed only up to 80% of the tax payable after deducting other tax allowances claimed by the distribution license holder.

Insurance tax

The basis for calculating the advance payment of the supplementary insurance premium tax is revised. Premiums from life insurance policies must be taken into account when calculating the supplementary tax base.

Retail tax

An amendment has taken effect regarding retail tax, increasing the thresholds for each tax bracket. The applicable retail tax is now 0% on the portion of the tax base not exceeding 1 billion forints; 0.15% on the portion not exceeding 50 billion forints; 1% on the portion not exceeding 150 billion forints; and 4.5% for the portion exceeding 150 billion forints. The tax rates themselves remain unchanged.

It is important to note that the increased thresholds must already be applied to the 2025 tax year when calculating the return. In case the taxpayer has an overpayment due to the tax advance payments, they are entitled to reclaim the overpaid amount.

As per the 2025 tax year, the special tax rates for motor vehicle fuel retail will remain in effect for the tax year beginning in 2026. When motor vehicle fuel is sold together with other products, the tax liability must be determined separately, applying the special rates to the fuel sale and the general rates to the other products sold.

Advertisement tax

The suspension of advertisement tax obligations will end on June 30, 2026. From July 1, 2026, entities subject to the advertisement tax must comply with the obligations set out in the Act on Advertisement Tax.

Beginning January 1, 2026, taxpayers subject to advertisement tax who are not yet registered with the state tax authority for any tax type must register using the authority’s official form within 30 days of commencing their taxable activity.

Transfer pricing

If parties agree on a retrospective adjustment to fair market value by the balance sheet preparation date, and implement it through accounting measures (e.g., via a credit or correction invoice), the taxpayer may choose not to adjust the intercompany price to the median of the market range.

Read a November 2025 report prepared by the KPMG member firm in Hungary