On 28 July 2026, the Hungarian Parliament adopted a legislative package concerning tax measures related to the Recovery and Resilience Plan (RRF), certain government programmes and government resolutions, as well as amendments to other legislation. Commonly referred to as the “summer tax package”, the amendments affect several areas of taxation, ranging from trust asset management and corporate income tax to retail tax, VAT, environmental load charges and certain minor taxes.
The most significant element of the package is the reform of the taxation of trust asset management arrangements.
The other amendments, however, do not form part of a comprehensive reform of the Hungarian tax system. One of the main objectives of the legislative package is to ensure that Hungary implements the tax reforms undertaken in connection with the Recovery and Resilience Plan by the deadline of 31 August 2026.
These include reviewing the taxation of trust asset management arrangements and private foundations, reducing the number of corporate income tax incentives, creating more uniform competitive conditions under the retail tax regime, and reducing the number of taxes, explained Viktor Szabó, Director of Tax Services at RSM Hungary.
It is important to note, however, that the impact of the newly adopted measures is far from universal. Some amendments affect only specific groups of businesses, while others concern individual, specific elements of the tax system. Certain measures may also result in an actual increase in the tax burden for the taxpayers concerned. The package therefore cannot be characterised uniformly as either a reduction in taxation or an easing of administrative obligations. Further tax changes are expected during the autumn parliamentary session, which may affect a considerably broader range of businesses.
Corporate income tax (CIT): certain incentives to be phased out
The corporate income tax amendments primarily affect businesses that currently apply the incentives or taxation arrangements being abolished.
- The growth tax credit scheme will be abolished from 1 January 2027. However, payment obligations relating to growth tax credits already elected by 31 December 2026 must continue to be fulfilled in accordance with the rules in force on 31 December 2026.
- From 2027, certain corporate income tax base allowances relating to historic monuments and buildings under individual local protection will also be phased out. This includes allowances connected with maintenance, investment and renovation, as well as allowances transferable to related parties. After the 2026 tax year, previously acquired but unused allowances may no longer be carried forward.
- Certain corporate income tax incentives relating to public-interest asset management foundations performing public duties (KEKVAs), as well as related “Robin Hood tax” incentives, will also be phased out. In this case, however, the amendments will take effect at a later date, from 1 August 2027.
The current amendments therefore do not amount to a comprehensive reform of the corporate income tax system. According to the official explanatory memorandum, the objective is to reduce the number of corporate income tax incentives, primarily by abolishing certain preferential provisions.
This also means that the current package does not involve either a change to the 9 per cent corporate income tax rate or the introduction of a two-tier corporate income tax system. Nevertheless, the role of corporate income tax in maintaining competitiveness, as well as the future tax incentives available for investment and research and development activities, remain important tax policy issues.
CIT calculation and preparation
Retail tax: a special aggregation rule is abolished
The retail tax amendment primarily affects retail businesses operating within related-party structures.
According to the explanatory memorandum, the aim of the amendment is to create more uniform competitive conditions under the retail tax regime.
Under the current rules, related companies are required in certain cases to aggregate their net revenue from retail activities. The tax must be calculated on the basis of the aggregated revenue and then allocated among the affected companies in proportion to their respective revenues.
The new rules abolish this special aggregation requirement. The businesses concerned will therefore determine their own tax liabilities and tax advances independently, in accordance with the general rules.
The amendment will already apply to tax years beginning in 2026, while the relevant provisions will enter into force on the day following the promulgation of the legislation.
The amendment may also affect the tax burden of the corporate groups concerned. It may therefore be advisable for these groups to recalculate their retail tax liability for 2026. We would also like to emphasise that the compliance obligations associated with related-party relationships have not been reduced in general; only the special aggregation of the retail tax base has been abolished. Based on our practical experience, the tax authority continues to impose strict requirements regarding transfer pricing documentation and reporting obligations on taxpayers conducting transactions with related parties.
VAT: previous invoice data reporting rules reinstated
In the area of VAT, the amendment represents the reversal of a previously introduced, broader data reporting obligation.
With regard to the rules applicable to incoming invoices, the provisions in force on 30 June 2026 will remain applicable from the tax assessment period that includes 1 July 2026. Accordingly, the additional data reporting requirement originally planned to take effect from 1 July, which would have required a more detailed breakdown of input VAT claimed, will not apply.
The amendment may be particularly relevant for businesses where IT developments relating to invoice processing and VAT return preparation, or the transition to the eVAT system, are already under way.
It is important to note, however, that this does not constitute a general reduction in VAT or a comprehensive simplification of VAT-related administration. One specific planned tightening of the reporting rules will not be implemented, while VAT digitalisation and the transition to the eVAT system may continue to require substantial changes to the processes and IT systems of the businesses concerned.
Environmental load charges: changes in opposite directions
The measures relating to environmental taxes and charges have conflicting effects.
The carbon dioxide quota tax will be abolished retroactively with effect from 7 October 2023. Taxpayers that have paid this tax since that date may request a refund of the tax paid and the related interest. Applications must be submitted within a statutory 90-day forfeiture period following the entry into force of the amendment, and additional conditions also apply to the refund.
This provision affects only taxpayers that previously paid carbon dioxide quota tax, but it may have a significant financial impact on those businesses.
At the same time, the unit rates of certain air pollution charges will double from 1 October 2026. The change will affect the rates applicable to emissions of sulphur dioxide, nitrogen oxides and non-toxic solid substances.
Businesses producing the emissions concerned, for which the amendment may therefore result in actual additional costs, should consider assessing the expected annual financial impact in advance.
These two measures clearly demonstrate that the summer tax package cannot be evaluated uniformly: even within the same area of taxation, there are both favourable amendments and changes resulting in additional burdens for taxpayers.
Local taxes: municipal tax to be abolished
The amendments relating to local taxation include the abolition of the municipal tax from 1 January 2027.
Until now, municipalities have been entitled to introduce, by means of a local decree, municipal taxes within their administrative territories, provided that the relevant tax was not prohibited by law. An example of such a tax is the tax imposed on watercraft. The summer tax package adopted by Parliament abolishes this option.
The reason for the change is that very few municipalities have made use of this taxing power. The measure will therefore also reduce the number of taxes in Hungary, which remains exceptionally high compared with other EU Member States.
The amendment primarily affects the taxing powers of municipalities. It is important to note that the traditional local taxes—including local business tax, building tax, land tax, tourism tax and communal tax—are not affected by the legislative amendment and will continue to be available to municipalities.
The package also clarifies the rules on advance payments and reporting obligations relating to local business tax in certain specific corporate situations, such as legal succession, demergers and spin-offs.
These provisions therefore do not represent a general change for all taxpayers subject to local business tax. They will primarily be relevant in connection with the specific transactions concerned.
Customs: changes to the rules for low-value transactions
Some of the customs-related amendments are intended to harmonise Hungarian legislation with changes in EU customs law.
From 1 August 2026, the payment relief applicable to customs duty and VAT amounts below EUR 10 will be abolished. This means that liabilities of this amount must also be paid. Similarly, the previous relief will no longer apply in the case of refunds.
The amendment may primarily be relevant for businesses involved in low-value import transactions. Companies operating e-commerce processes should therefore pay particular attention to the practical implications of the change.
The package also establishes the legislative framework for the automated adoption of certain customs authority decisions and the further development of electronic customs procedures.
Several minor taxes to be abolished
As mentioned above, the legislative package also includes a series of measures aimed at reducing the number of taxes. From 1 January 2027, the dog control contribution and the immigration surtax will be abolished alongside the municipal tax.
The abolition of these taxes will not directly affect the majority of taxpayers.
Nevertheless, the measures are consistent with the official objective of reducing the number of taxes and simplifying certain elements of the tax system.
What does all this mean for the Hungarian tax system?
The summer tax package undoubtedly contains several important amendments, but their impact may differ considerably among different groups of taxpayers.
For some businesses, the amendments may result in a reduction in their tax burden or enable them to reclaim taxes previously paid. Others—such as taxpayers subject to the affected air pollution charges—will face additional costs. Certain amendments merely mean that a previously planned tightening of the rules will not be implemented, while others will become relevant only in specific corporate situations.
The package as a whole should therefore not be regarded as either a general reduction in taxation or a general easing of administrative obligations.
According to the official explanatory memorandum, a significant proportion of the current measures are intended to implement the tax reforms undertaken under the RRF. These include reviewing the taxation of trust asset management arrangements, reducing the number of corporate income tax incentives, creating more uniform competitive conditions under the retail tax regime, and reducing the number of taxes.
From this perspective, the “summer tax package” should be regarded as an important stage in an ongoing process rather than a comprehensive transformation of the Hungarian tax system.
The major competitiveness issues may emerge in the autumn
From a competitiveness perspective, the Hungarian tax system could accommodate considerably more substantial reforms.
For businesses, it is not only the current level of individual tax rates and incentives that matters. The long-term predictability of the tax environment, the availability of incentives for investment and innovation, and the extent to which businesses are burdened by sector-specific taxes are equally important.
The future of tax incentives for research and development activities, as well as the future structure of sector-specific surtaxes, may therefore become particularly important issues. These are no longer merely technical questions affecting the tax liabilities of specific groups of taxpayers; they may also influence businesses’ investment and commercial decisions.
The current package does not, however, indicate that answers to these questions have already been found. Although Parliament’s customary “summer recess” did not take place this year, the adoption of this legislative package presumably marks only the end of the first major stage in the amendment of the tax legislation.
The summer tax package is therefore an important step—but the substantive changes affecting a broader range of businesses are likely to be introduced as part of the autumn tax package.
