On 12 July 2019, the Hungarian legislator passed an anti-tax avoidance rule for the implementation exit tax and hybrid mismatch rules in line with the EU Anti-Tax Avoidance Directive (ATAD).
The exit tax rules would apply from 1 January 2020 and provide that taxes are levied on the amount equal to the market value of the transferred assets less their taxable value when transferring assets from Hungary so that they no longer fall within the scope of the Hungarian taxation. Subject to certain conditions, where assets are transferred to an EU or EEA Member State, the exit tax may be paid in installments over five years. The hybrid mismatch rules would also generally apply from 1 January 2020 and primarily provide for the dis-allowance of a deduction in the case of hybrid mismatches.
