Hungary to raise corporate tax to 15% for large companies from 2027 with other major tax changes ahead

On 27 October 2026, the Hungarian government submitted Bill T/931 to Parliament, which would overhaul corporate income tax for large companies and amend several sector-specific taxes, with most rules applying from 1 January 2027. The bill is part of the autumn tax package substantially reforming the Hungarian tax system. Our Articles on the new wealth tax, KATA overhaul and other changes can be found here.

A two-tier corporate tax system

The 9% rate would remain for most businesses. Companies, however, whose consolidated (under Hungarian accounting rules, IFRS or another EU/EEA national framework) or, absent consolidation, standalone annual revenue reached EUR 500 million in the second preceding tax year would pay 15%. For groups, the revenue in the highest-level consolidated accounts would apply and smaller companies could opt into the regime. If a single member of a tax group qualifies, the whole group would pay the higher rate.

The bill introduces two similar but distinct terms. A “large company” (nagyvállalat) is the new category subject to the 15% rate and the special tax-base rules, determined by the EUR 500 million revenue test. A “large enterprise” (nagyvállalkozás) is simply any business that is not an SME, regardless of revenue. The latter is relevant only for the development tax allowance, where large enterprises face additional R&D conditions. A company can be a large enterprise without being a large company.

Large companies would calculate their tax base separately, including deferred tax adjustments and a narrower dividend exemption requiring a stake of at least 10% or a 12-month holding period. Most cost-based tax base reductions and tax credits, other than the R&D tax credit, would be capped at the lower of 5.5% of the higher of payroll costs or depreciation, and 1% of the book value of tangible assets. Partly offsetting this, 85% of local business tax could be deducted from corporate tax payable, up to 25% of the tax due.

Tax groups and shareholdings

Tax groups would in future be based on inclusion in consolidated financial statements rather than 75% control, although existing groups could continue under the current rules as long as they meet them. The notified shareholding regime would be replaced by a new qualifying shareholding concept: capital gains on stakes of at least 10% held for at least one year would be exempt without prior notification while related losses would not be deductible.

More generous but targeted R&D incentives

Researchers’ staff costs and the depreciation of the assets they use would effectively count three times in the tax base, and the R&D tax credit would double from 10% to 20% of eligible costs, without the current five-year election requirement. Outsourced R&D, however, would only qualify if purchased from SMEs, universities, university clinics or listed research institutions. For investments started from 2027, large enterprises (i.e. any non-SME) claiming the development tax allowance would need to increase R&D spending by at least 5% annually.

Other significant changes

• The corporate tax credit for supporting spectator team sports would end from 2027 and be replaced by a 20% tax base deduction for donations to amateur sport.
• The innovation contribution would rise from 0.3% to 0.5%.
• The bank extra-profit tax would remain in place for 2027 at unchanged rates, calculated on 2025 results.
• The retail tax’s second-lowest rate would rise from 0.15% to 0.45%.
• Energy suppliers’ income tax (i.e. the Robin Hood tax) payers qualifying as large companies would apply the large-company tax base rules. Impairment on shareholdings and interest on related-party loans would increase the tax base.
• The insurance tax bands would be abolished from 2027, so uniform rates would apply to all insurers in each line of business. The insurance surtax would remain for 2027.
• The financial transaction tax-free threshold for transfers from private individuals' payment accounts would rise from HUF 50,000 to HUF 150,000 per transfer. The 0.45% rate would remain unchanged, but the cap per transfer would increase from HUF 20,000 to HUF 30,000. 

Recommended next steps

Although the bill’s final text may change, affected parties should start assessing their position now. Groups near the EUR 500 million threshold should model the effect of the 15% rate and the incentive cap, and review group structures, R&D sourcing and investment timing before year-end.

For more information on the new corporate tax regime 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.