Hungary’s proposed new 2027 tax package includes exit tax, advertising tax and mandatory eVAT

On 27 October 2026, the Hungarian government submitted Bill T/927 to Parliament, which amends personal income tax, corporate tax, VAT, excise duty, the advertising tax, company car tax, tax procedure and accounting rules, with most changes applying from 1 January 2027. 

The bill forms part of an autumn tax package that would substantially reshape the Hungarian tax system. Our articles on the 15% corporate tax rate for large companies, wealth tax, KATA overhaul and other changes can be seen here.

Exit tax for individuals leaving Hungary

Individuals giving up Hungarian tax residence would be taxed on the unrealised gains on assets such as securities, shareholdings, crypto-assets and long-term investment accounts. Specific rules would also capture assets held through trusts and private foundations. The rules would apply only to individuals resident in Hungary in at least five of the previous ten tax years whose relevant assets exceed HUF 500 million, or who hold a shareholding of at least 20% worth at least HUF 250 million and only where Hungary loses or limits its right to tax later gains. 

Having considered the case-law of the CJEU on exit tax arrangements, a move to another EU or EEA state would trigger an automatic, interest-free deferral. The deferral would end on realisation, a gratuitous transfer, a withdrawal of value above 25%, a later move to a third country or a failure to meet annual reporting duties. On a direct move to a third country, the tax would be payable by the deadline for the annual tax return.

Revival of the advertising tax

The advertising tax, suspended through a 0% rate, would be revived from 2027 with progressive rates of 0% up to HUF 500 million, 2.5% up to HUF 10 billion, 4.5% up to HUF 40 billion and 7.5% above that. The tax bases of related companies would again be aggregated, and the register of compliant publishers would be restored. Advertisers would face a 2.5% rate, instead of the previous 5%, if their publisher is not on the register and does not confirm its own compliance.

Mandatory eVAT and other VAT changes

Transaction-level electronic VAT returns (eVAT) would become mandatory from 1 July 2027 for the largest taxpayers filing monthly returns and from 1 January 2028 for taxpayers generally. The bill would also implement the ViDA Directive, including an extended deemed supplier role for platforms. The 5% VAT rate on new homes would apply without an end date.

Stricter anti-abuse rules

The general anti-abuse rule would be rewritten, listing typical abusive arrangements such as transactions aimed primarily at a tax advantage without real economic reasons, artificial chains of transactions and the interposition of intermediaries without economic justification. Where the tax authority’s evidence makes abuse likely, the taxpayer would have to prove that the arrangement had genuine commercial reasons and follows arm’s-length practice.

Other relevant changes

• The rehabilitation contribution, currently nine times the minimum wage per person per year, would rise for employers with at least 250 employees, to 11, 13 or 15 times the minimum wage depending on headcount.
• Company car tax rate would become gradual for cars above 120 kW, and vehicle tax would be deductible for only one car.
• Social contribution tax on remuneration-type employee share ownership programme payments would no longer be capped and would be paid by the payer; for programmes launched before 2027, this would apply only to payments made after 2028.
• The revenue threshold up to which restaurant entertainment is tax-free would fall from HUF 100 million to HUF 50 million.
• Athletes and coaches would lose their higher thresholds for the simplified public contribution tax (ekho) and could opt for it only up to the general HUF 60 million annual limit.
• Transfer pricing data would have to be filed on a separate form instead of in the corporate tax return.
• Excise duty on spirits and intermediate products would rise by 12%, the cigar tax would increase, and the excise advance payment threshold would double to HUF 12 million per quarter.

Recommended next steps

Although the final text may change, affected parties should start assessing their position now. Advertising publishers should model their 2027 tax exposure, large taxpayers should prepare their systems for eVAT, employers with at least 250 employees should budget for the higher rehabilitation contribution, and individuals planning a move abroad should review their exposure to the exit tax.

For more information on the 2027 tax package and its practical implications, contact your CMS client partner or the CMS experts who wrote this article.

This article was co-authored by Botond Nagy and Hunor-Bendegúz Jávorszki.