Updated for 2025
Explore the special regimes of corporate taxation in Hungary for 2025, including fiduciary asset management, tax-neutral reorganizations, and corporate tax benefits for donations and energy efficiency investments.
Keywords:
Corporate tax Hungary 2025, Hungarian fiduciary tax, tax-neutral corporate reorganizations, corporate donations Hungary, Hungarian corporate deductions, intangibles taxation Hungary, SME tax Hungary
—
This article is the second part of our seven-part series on corporate taxation in Hungary. After introducing the [Basic Framework of Corporate Tax in Hungary](), this part focuses on Special Regimes, which includes unique rules for fiduciary asset management, reorganizations, currency choice, intangibles, and corporate donations. Future installments will cover topics like extra profit tax, cross-border taxation, anti-avoidance rules, corporate asset investments, and penalties for non-compliance.
—
🧾 1. No Regional Tax Incentives
Hungarian corporate tax law does not grant special regimes based on specific business zones or regional sectors.
—
🛡️ 2. Fiduciary Asset Management (Trust Regime)
Hungarian law allows for special tax treatment of assets placed under fiduciary asset management:
Tax- and duty-neutral transfer: Transferring assets to a fiduciary (trustee) is not subject to tax or duty for either party.
Initial capital treatment: The value of assets transferred becomes the initial capital of the trust.
Tax-free distribution: When capital is later distributed to beneficiaries, it is tax-free up to the amount of the initial capital; only excess value is taxable.
Corporate tax exemption: Trust assets are generally subject to corporate and municipal tax but may be exempt if:
Both the settlor and the beneficiaries are individuals, and
The trust assets only include financial instruments (e.g., shares, stocks).
—
🔄 3. Tax-Neutral Corporate Reorganizations
The following corporate transactions are generally tax-neutral if the same entities are involved on both the transferor and transferee sides:
Mergers
Spin-offs
Capital contributions of going concerns
Certain share-for-share exchanges
—
💱 4. Currency of Accounting
Hungarian companies may maintain accounting in a foreign currency:
EUR or USD can be freely chosen.
Other currencies are allowed only if they qualify as the company’s functional currency.
—
5. Intangibles and Depreciation
There are no special tax rules for intangibles. However:
Intangibles qualifying as fixed assets are subject to straight-line depreciation.
Depreciation is based on acquisition or production cost, and limited to the maximum rates defined by law.
—
📉 6. Business Deductions
Hungarian law defines allowable corporate deductions as those that are “ordinary and necessary” for the business sector. Deductible categories include:
Direct and indirect expenses
Interest on debt
Labour costs
Mandatory employer contributions to employee pensions
—
7. Special Tax Deductions
Corporate tax liability may be reduced through certain targeted donations or investments, such as:
Donations to spectator sports teams (e.g., football, handball, water polo)
Support for Hungarian film production
Donations to Cooperative Community Basic Education
Interest on SME investment loans
Energy-efficiency investments or renovations
Donations to live music services
—
📌 Legal Notice
This article provides a general overview of Hungary’s corporate tax law as of 2025 and is not to be considered legal or tax advice. For tailored advice, please consult our law firm
Dr. Katona Géza, LL.M. ügyvéd (Rechtsanwalt / attorney at law)
___________________________________
Katona és Társai Ügyvédi Társulás
(Katona & Partner Rechtsanwaltssozietät / Attorneys’ Association)
H-1106 Budapest, Tündérfürt utca 4.
Tel.: +36 1 225 25 30
Mobil: + 36 70 344 0388
Fax: +36 1 700 27 57
Corporate Tax in Hungary (Part 2): Special Regimes
Updated for 2025
Explore the special regimes of corporate taxation in Hungary for 2025, including fiduciary asset management, tax-neutral reorganizations, and corporate tax benefits for donations and energy efficiency investments.
Keywords:
Corporate tax Hungary 2025, Hungarian fiduciary tax, tax-neutral corporate reorganizations, corporate donations Hungary, Hungarian corporate deductions, intangibles taxation Hungary, SME tax Hungary
—
This article is the second part of our seven-part series on corporate taxation in Hungary. After introducing the [Basic Framework of Corporate Tax in Hungary](), this part focuses on Special Regimes, which includes unique rules for fiduciary asset management, reorganizations, currency choice, intangibles, and corporate donations. Future installments will cover topics like extra profit tax, cross-border taxation, anti-avoidance rules, corporate asset investments, and penalties for non-compliance.
—
🧾 1. No Regional Tax Incentives
Hungarian corporate tax law does not grant special regimes based on specific business zones or regional sectors.
—
🛡️ 2. Fiduciary Asset Management (Trust Regime)
Hungarian law allows for special tax treatment of assets placed under fiduciary asset management:
Tax- and duty-neutral transfer: Transferring assets to a fiduciary (trustee) is not subject to tax or duty for either party.
Initial capital treatment: The value of assets transferred becomes the initial capital of the trust.
Tax-free distribution: When capital is later distributed to beneficiaries, it is tax-free up to the amount of the initial capital; only excess value is taxable.
Corporate tax exemption: Trust assets are generally subject to corporate and municipal tax but may be exempt if:
Both the settlor and the beneficiaries are individuals, and
The trust assets only include financial instruments (e.g., shares, stocks).
—
🔄 3. Tax-Neutral Corporate Reorganizations
The following corporate transactions are generally tax-neutral if the same entities are involved on both the transferor and transferee sides:
Mergers
Spin-offs
Capital contributions of going concerns
Certain share-for-share exchanges
—
💱 4. Currency of Accounting
Hungarian companies may maintain accounting in a foreign currency:
EUR or USD can be freely chosen.
Other currencies are allowed only if they qualify as the company’s functional currency.
—
5. Intangibles and Depreciation
There are no special tax rules for intangibles. However:
Intangibles qualifying as fixed assets are subject to straight-line depreciation.
Depreciation is based on acquisition or production cost, and limited to the maximum rates defined by law.
—
📉 6. Business Deductions
Hungarian law defines allowable corporate deductions as those that are “ordinary and necessary” for the business sector. Deductible categories include:
Direct and indirect expenses
Interest on debt
Labour costs
Mandatory employer contributions to employee pensions
—
7. Special Tax Deductions
Corporate tax liability may be reduced through certain targeted donations or investments, such as:
Donations to spectator sports teams (e.g., football, handball, water polo)
Support for Hungarian film production
Donations to Cooperative Community Basic Education
Interest on SME investment loans
Energy-efficiency investments or renovations
Donations to live music services
—
📌 Legal Notice
This article provides a general overview of Hungary’s corporate tax law as of 2025 and is not to be considered legal or tax advice. For tailored advice, please consult our law firm
Dr. Katona Géza, LL.M. ügyvéd (Rechtsanwalt / attorney at law)
___________________________________
Katona és Társai Ügyvédi Társulás
(Katona & Partner Rechtsanwaltssozietät / Attorneys’ Association)
H-1106 Budapest, Tündérfürt utca 4.
Tel.: +36 1 225 25 30
Mobil: + 36 70 344 0388
Fax: +36 1 700 27 57