Act XXXV of 2026 on Tax Measures Necessary for the Implementation of the Recovery and Resilience Plan and on the Amendment of Other Acts (the “Act”) was promulgated in the Hungarian Gazette of 30 July 2026. The Act amends several tax laws.

The most important changes concern asset management trusts, corporate income tax, retail tax, local business tax and the reporting obligation related to VAT returns. In addition, the Act also amends other tax legislation and taxes, including environmental charges, customs duties and municipal taxes. In this material, however, we intend to provide a general overview of only the more important changes, without claiming to be exhaustive.

Changes affecting asset management trusts (“AMTs”)

The new rules affecting asset management trusts must be applied from 31 August 2026. We recommend that anyone already using such an arrangement or planning to establish such a structure before the Act enters into force examine separately which of the newly introduced rules apply to them and in which cases they may proceed under the previous rules.

The essence of the amendment is that while the revaluation of an asset upon its transfer into trust – that is, the positive difference between the accounting value at which the asset is recognised in the trust assets and its previous acquisition value – would still not give rise to an immediate tax payment, the tax advantage available after five years will cease to exist and will be replaced by tax deferral. Accordingly, payments charged against the initial capital would in most cases qualify as dividend income in the future. An exception applies if the asset is returned in an unchanged form. In other cases, the acquisition value of the asset at the settlor is also excepted from the return of the asset. In this context, the order of payments will be reintroduced, the concept of unchanged form will be defined and special rules applicable to crypto-assets will also be introduced.

As a new element, the Act clarifies the tax treatment of assets made available free of charge or at a reduced rate. It also requires the trustee to submit data for each tax year by 31 January of the year following the tax year, with the data for 2026 due by 31 March 2027.

Another important amendment is the introduction of mandatory tax audits. The Act expressly provides that the National Tax and Customs Administration will audit, first, trust assets registered before 12 September 2023 and, after 1 January 2028, all assets held in asset management trusts and all private foundations, within the limitation period for the right to assess tax. During these audits, the tax authority may examine, among other matters:

• the manner in which the business relationship with the adviser or countersigning lawyer was initiated, its purpose and economic circumstances, as well as the content of draft written documents related to the trust assets;
• the service agreement concluded with the lawyer or adviser and any provisions of the engagement agreement related to the tax advantage, such as a “success fee” determined as a percentage of the tax advantage achieved;
• the period between the transfer of the assets into trust and the first distribution of assets treated as capital, as well as the reason triggering the distribution.

Changes affecting corporate income tax

The tax base allowance related to support provided to public-interest asset management foundations performing public duties will cease to apply from 1 August 2027.

The tax allowances related to historic monuments will be phased out from 1 January 2027. The tax base may be reduced under this title for the last time in the 2026 tax year, and unused allowances may not be carried forward.

The allowance for the maintenance of historic monuments will cease to apply at the end of the 2026 tax year.

The growth tax credit will also be phased out. For tax credits that arose before 2027 and are still ongoing, the taxpayer must pay the tax amount in accordance with the rules and schedule in force on 31 December 2026.

Subject to certain conditions, the amount of the growth tax credit that has not yet become due may be reduced if the taxpayer carries out an investment in tangible assets and increases its headcount. This quasi-investment allowance will no longer be available for growth tax credit instalments due after December 2026. This also means that growth tax credit instalments may no longer be reduced under the investment allowance from 2027.

The 300% tax base allowance available in connection with a support agreement concluded with a university maintained by a public-interest asset management foundation performing public duties, or with its maintainer, may be claimed for the last time in the 2027 tax year.

Retail tax

Currently, an aggregation rule applies to the retail tax base. Accordingly, related companies that outsourced their activities or transferred the assets required for those activities to a related company after the promulgation of the government decree introducing the retail tax were required to aggregate their tax bases.

The taxpayer was exempt from this rule if it proved that the transaction concerned had been carried out exclusively for economic reasons and not for tax avoidance purposes.

The Act repeals this aggregation rule in its entirety due to its restrictive effect on competition in the retail sector.

Value added tax

In line with the Government’s earlier communication ([link]), the more detailed reporting obligation will not become mandatory from 1 July 2026.

This means that, after 1 July 2026, VAT return M forms must continue to contain the data required under the rules in force on 30 June.

The exact date on which the extended reporting obligation will actually be introduced is not yet known. However, with the future introduction of eVAT and the phasing-out of the General Form Completion Framework (ÁNYK), amendments concerning the M forms will become redundant.

Local business tax

More favourable rules will apply to hive-down transformations. A hive-down is a special form of division in which a new legal entity is established by separating from its legal predecessor, with the legal predecessor becoming its sole member. Consequently, the owners of the legal predecessor do not become the owners of the new legal entity, as they would in the case of a split-up or spin-off.

For this situation, the Act introduces a simplification allowing the legal predecessor to fulfil the notification and local business tax advance return obligations of the successor created through the hive-down in the tax year concerned. The legal predecessor does so by means of a declaration, which qualifies as a tax return. As a result, the local tax authority divides the tax advance payment obligation between the entities in a 50–50% ratio. The legal predecessor may also request the transfer of any overpayment to the successor’s tax account.