This article is the sixth part of a seven-part series on corporate taxation in Hungary. Following the introduction of basic corporate tax rules and special tax systems, this part focuses on the fight against tax avoidance.
Hungary has fully implemented the EU Directive 2016/1164 (ATAD) as well as its amending directive, EU Directive 2017/952 (ATAD 2), which aim to introduce rules against tax avoidance, particularly to prevent abuses arising from hybrid structures and hybrid transactions.
Under Hungarian tax law, the tax authority may disregard the tax consequences of transactions that lack economic substance and are aimed solely at obtaining a tax advantage. Such tax advantages may be invalid if they contradict the objectives and principles of the tax system.
The Hungarian tax system includes several provisions that align with the European Union’s rules on hybrid structures and tax avoidance methods. These procedures exploit situations where the parties involved are registered in different member states, and payments between them are treated differently by those member states. As a result, neither party considers the payment in their tax base, leaving it untaxed.
If, due to differing tax qualifications, an expense or cost cannot be deducted from the corporate tax base, the anti-hybrid rules prevent such a deduction. This can be avoided if the company requests a binding ruling from the tax authority regarding the matter, and the authority accepts it.
The binding ruling can be requested for future transactions, or for transactions that are no longer considered future but are based on essential factual information. The fee for this ruling procedure is 10,000,000 HUF (ten million Hungarian forints) for a standard agreement. The ruling is valid until the end of the fifth tax year following its issuance and may be extended once for an additional two years. The ruling is only binding on the tax authority if the facts of the case remain unchanged.
This article provides general information about corporate taxation and anti-tax avoidance rules in Hungary and does not constitute specific legal advice.
Katona és Társai Ügyvédi Társulás
(Katona & Partner Rechtsanwaltssozietät / Attorneys’ Association)
H-106 Budapest, Tündérfürt utca 4.
Tel.: +36 1 225 25 30
Mobil: +36 70 344 0388
Fax: +36 1 700 27 57
[g.katona@katonalaw.com](mailto:g.katona@katonalaw.com)
[www.katonalaw.com](http://www.katonalaw.com)
Corporate Taxation in Hungary (Part 6): Measures Against Tax Avoidance (Updated: 2025)
This article is the sixth part of a seven-part series on corporate taxation in Hungary. Following the introduction of basic corporate tax rules and special tax systems, this part focuses on the fight against tax avoidance.
Hungary has fully implemented the EU Directive 2016/1164 (ATAD) as well as its amending directive, EU Directive 2017/952 (ATAD 2), which aim to introduce rules against tax avoidance, particularly to prevent abuses arising from hybrid structures and hybrid transactions.
Under Hungarian tax law, the tax authority may disregard the tax consequences of transactions that lack economic substance and are aimed solely at obtaining a tax advantage. Such tax advantages may be invalid if they contradict the objectives and principles of the tax system.
The Hungarian tax system includes several provisions that align with the European Union’s rules on hybrid structures and tax avoidance methods. These procedures exploit situations where the parties involved are registered in different member states, and payments between them are treated differently by those member states. As a result, neither party considers the payment in their tax base, leaving it untaxed.
If, due to differing tax qualifications, an expense or cost cannot be deducted from the corporate tax base, the anti-hybrid rules prevent such a deduction. This can be avoided if the company requests a binding ruling from the tax authority regarding the matter, and the authority accepts it.
The binding ruling can be requested for future transactions, or for transactions that are no longer considered future but are based on essential factual information. The fee for this ruling procedure is 10,000,000 HUF (ten million Hungarian forints) for a standard agreement. The ruling is valid until the end of the fifth tax year following its issuance and may be extended once for an additional two years. The ruling is only binding on the tax authority if the facts of the case remain unchanged.
This article provides general information about corporate taxation and anti-tax avoidance rules in Hungary and does not constitute specific legal advice.
Katona és Társai Ügyvédi Társulás
(Katona & Partner Rechtsanwaltssozietät / Attorneys’ Association)
H-106 Budapest, Tündérfürt utca 4.
Tel.: +36 1 225 25 30
Mobil: +36 70 344 0388
Fax: +36 1 700 27 57
[g.katona@katonalaw.com](mailto:g.katona@katonalaw.com)
[www.katonalaw.com](http://www.katonalaw.com)