The Hungarian Parliament passed legislation to retroactively implement the Pillar 2 global minimum tax (GloBE) on 21 November 2023.
Hungary’s parliament approved two bills (T/12802/7 and T/12801/12) on 18 November 2025 that introduce significant updates to the country’s tax framework and reporting obligations.
Among the key changes, the legislation revises Hungary’s global minimum tax rules, ensuring that large multinational groups pay at least a 15% tax on their revenues, a measure aligned with half of the OECD’s global tax agreement.
The bills also extend the suspension of the turnover-based advertising tax until 30 June 2026, and bring national law in line with EU transparency requirements for crypto assets.
Additionally, the updated global minimum tax rules refine the transitional country-by-country reporting system by creating a simplified “covered tax” framework, providing clarity and easing compliance for affected companies. The bills also focused on changes to clarify transfer pricing documentation and accounting, as well as on modernising the value added tax (VAT) administration.
Corporate taxation and alignment with global standards
Hungary is adapting its domestic laws to align with international cooperation efforts, specifically by incorporating EU directives on the global minimum tax level (Pillar 2).
Global minimum tax reporting (pillar two)
For domestic group members subject to the Minimum Tax Act, the modification introduces centralised data reporting serving as an administrative simplification. The reporting member must identify the relevant parts of the supplementary tax report and the affected jurisdictions to which the information must be shared automatically.
The initial reporting period covered by this exchange framework begins for tax years starting after 31 December 2023. The state tax and customs authority (NAV) is scheduled to first transmit this supplementary tax information after 1 December 2026.
Failure or delay in meeting filing obligations related to the global minimum tax framework can result in significant penalties. Mismatches, delays, or omissions in reporting obligations associated with this supplementary tax may incur a penalty of HUF 10 million.
Corporate incentives: R&D deductions
Specific maximum percentages for tax benefits derived from research and development (R&D) expenditures have been introduced into the Corporate Tax Act. These limits are:
- 100% of the deductible cost for basic research.
- 50% of the deductible cost for applied (industrial) research.
- 25% of the deductible cost for experimental development.
Transfer pricing
Changes have been introduced to the Accounting Act concerning the treatment of the difference between the applied consideration and the arm’s length price (or arm’s length price range) established for related-party transactions under the Corporate Tax Act.
If the price difference (between the transaction price and the arm’s length price/range) would typically require a subsequent modification of the corporate tax base, the parties, by agreement, may account for this difference retroactively, up to the date of balance sheet preparation.
These accounting rules concerning transfer pricing adjustments are mandatory for financial statements prepared for business years starting in 2026. However, they may optionally be applied to reports prepared for business years beginning in 2025.
VAT reforms
The VAT regulations are undergoing significant administrative changes, focusing on compliance, group taxation, and the frequency of returns. A key shift is the introduction of a new obligation for taxpayers to provide detailed data regarding incoming invoices upon which they exercise their right to deduct input VAT.
This reporting obligation will first apply to VAT returns covering tax assessment periods that include 1 July 2026.
Restrictions on accelerated VAT filing
Taxpayers who file annual VAT returns may request permission to file quarterly returns, and those who file quarterly may request permission to file monthly.
New reduced VAT rate
A new 5% VAT rate will apply to domesticated bovine meat (fresh, chilled, or frozen) for supplies made on or after 1 January 2026.
On 21 November 2023, the Hungarian Parliament passed legislation to implement the Pillar 2 global minimum tax (GloBE) rules under the Council Directive (EU) 2022/2523 of 14 December 2022.
