We would like to bring to your attention to the most important amendments to Hungarian law concerning the Global Minimum Tax, special sectoral taxes, extra profit taxes and local taxes, relevant for 2025.
GLOBAL MINIMUM TAX
reporting obligations
Further details had been announced regarding
the reporting obligations of domestic group members on tax subject status for
the global minimum tax. The reporting is due already by December 31, 2024. In
addition to the structure of the group, the details and qualifications of the
group members, including the proportion of top up tax for the GloBE assigned to
them must also be indicated. The designated representative shall act on behalf
of all domestic group members.
domestic advance
Group members must declare and pay a recognised domestic advance tax for the global minimum top-up tax (QDMTT advance) by the 20th day of the eleventh month from the last day of the tax year to which the recognised domestic additional tax relates. Meaning the first advance payment obligation for Globe in Hungary respective to FY2024 already by November 20, 2025, for calendar tax years. The amount of the tax advance shall be equal to the total amount of the recognised national top-up tax. The designated local organization may submit one return on behalf of all the Hungarian group members. For the time being, there will be no sanctions due to miscalculation.
SPECIAL SECTORAL TAXES, EXTRA-PROFIT TAXES
extra-profit taxes
From 2025 certain type of extra-profit taxes
will ceased to be exist, especially the special tax on producers of petroleum
products, energy producers, balancing service providers and pharmaceutical
manufacturers, as well as the extra profit tax on pharmaceutical manufacturers,
the obligation of distributors of pharmaceuticals and medical aids, the
obligation of manufacturers to pay income tax on energy suppliers, the
telecommunications surcharge, the surcharge payable by mining contractors in
the absence of a contract and contributions of airlines.
Retail tax on platform operators
From January 1, 2025, domestic
and foreign organizations operating online marketplaces and platforms that
provide sales platforms to sellers engaged in retail activities will also
become subject to retail tax. Thus, the platform operator becomes the taxpayer
and will be liable to pay tax on the aggregate amount of net turnover from the
sale of goods sold through the platform. There are several detailed rules for
calculating the tax base.
Financial transaction duty
The increased additional financial transaction duty for exchange transactions between different currencies has been enacted into law amounting to 0.45%, up to a maximum of HUF 20,000 (approx. EUR 50), which must be paid in addition to the normal transaction levy. The additional duty shall apply to transfers between accounts of domestic customers and to payment transactions by financial and investment firms, but not to bank card transactions. For bank transfers 0.45% per transaction, but not more than HUF 20,000 (approx. EUR 50) per transaction, while 0.9% for cash withdrawals is payable without an upper ceiling
LOCAL TAXES
Storage structures related to livestock and crop production will be exempt from the tax
A foreign air passenger transport operator whose state of residence is a party to the Chicago Convention on International Civil Aviation deemed not to have an establishment and thus a local business tax liability. The exemption can already be applied for 2024.
Scope of data required by municipalities for tax purposes, is determined, and will by electronic means automatically provided by the state tax authority to the municipalities on a daily basis.
Special economic zones are abolished: Göd, Iváncsa, Mosonmagyaróvár and Paks.