New Tax Rules from 2025: How the Latest Tax Package Affects Wealth Transfers and Foundation Structures
On June 19, 2025, Act LIV of 2025 was adopted, making numerous amendments to tax obligations and tax laws, particularly focusing on the taxation of wealth transfers and wealth management foundations. Below, our office summarizes the key changes, highlighting the legal and tax considerations affecting both individuals and corporate wealth management.
Dividend Claim Transfers – The End of Old Interpretations?
In March 2025, a tax authority clarification was issued, stating that when a dividend claim is transferred to a trust, the individual incurs taxable income, even if the dividend is not actually paid out. This interpretation sparked significant debate within the professional community, as it had not previously been clearly derived from the Personal Income Tax (PIT) Act.
The newly adopted amendment clarifies:
➡️ Dividend claim transfers are considered an exercise of the right of disposal,
➡️ therefore, tax liability arises, with 15% personal income tax (PIT) and 13% social security tax (SZOCH) up to the applicable upper limit.
This regulation elevates the tax authority’s stance to the level of law, a position that was previously debatable. Practically, this means that individuals facing wealth transfers in the future must prepare for significant tax risks, even if the claim is not realized.
Retroactive Application? – Room for Defense in Tax Litigation
A key issue is whether the new interpretation can be applied retroactively. Our position is that this is legally questionable for wealth transfers made before June 19, 2025, as it may conflict with the prohibition of retroactive legislation. In the case of tax audits or litigation, the taxpayer may still have strong defense arguments, especially if the legal interpretation was not clear previously.
What Can Individuals Planning a Wealth Transfer Do Now?
It is recommended to assess and minimize the tax risks associated with wealth transfers by seeking targeted legal and tax advice. The specific circumstances – especially the purpose and documentation of the transfer – can play a crucial role.
New Regulations for Foundation Structures – Introducing the Long-Term Wealth Management Relationship
The changes affecting wealth management foundations aim to standardize the tax and accounting treatment of these structures. The amendment will come into effect on September 1, 2025, and introduces the concept of long-term wealth management relationship.
The goal is for wealth managed by a foundation to be treated the same as wealth managed under a trust agreement as defined by the Civil Code in terms of taxation.
Key Changes from September 2025:
• The wealth managed by the foundation will become an independent tax entity, subject to its own bookkeeping requirements.
• The foundation’s financial statements for managed wealth will not be publicly disclosed, similar to trust management.
• Corporate tax exemption will still apply if the managed wealth is linked only to individuals and the wealth generates financial results.
Detailed rules are still being developed, so stakeholders involved in foundation structures should actively monitor legislative developments and prepare for the required accounting and legal compliance.
Summary – What Does Our Law Firm Recommend?
Legal representation and advice are crucial for interpreting and applying the new rules.
Before making wealth transfer decisions, it is advisable to request personalized tax planning and structure analysis.
Participants in foundation models should prepare in advance for the new bookkeeping and compliance obligations.
Contact us with confidence if you or your company are involved in wealth management or foundation structures affected by these changes!
We assist in minimizing tax risks, developing the right structure, and representing you in proceedings before the tax authorities.
Dr. Géza Katona, LL.M. – Attorney-at-Law (Rechtsanwalt / Attorney-at-Law)
📍 1106 Budapest, Tündérfürt Street 4.
📞 +36 1 225 25 30 | 📱 +36 70 344 0388
📠 Fax: +36 1 700 27 57
✉️ g.katona@katonalaw.com
🌐 www.katonalaw.com