Wealth tax and exit tax in Hungary: What should be your next steps?

Dr. Robin Bordás, lawyer, tax advisor | BRDS Tax & Legal | November 1, 2026

The government submitted the wealth tax bill on October 27, 2026, and on the same day a separate tax package that introduces the exit tax institution in Hungary . The text has changed on sixteen points since the social consultation. Below, I will summarize what was decided, where the system still limps, and what is worth doing for those who may be affected — because there are eight weeks left until the first value date.

The calendar is more important than the tax rate

The law would enter into force on December 15, 2026 , but the first tax liability arises based on the financial situation on December 31, 2026 ; the deadline for filing and paying is August 31, 2027. The first "snapshot" will therefore be prepared a few weeks after the announcement.

The parameters have not changed: 1% of the tax base up to HUF 100 billion, 1.5% for the part above that. The tax base is the net wealth — the value of the assets minus the certified debts — reduced by the HUF 1 billion threshold , which applies to each taxpayer. Taxable persons are domestic individuals (for worldwide assets), foreigners (for Hungarian real estate and Hungarian company shares), as well as asset management taxpayers: trusts, private foundations and their foreign equivalents. It is important that the rules of residence differ from those usual in personal income tax.

Who is it really about?

The impact assessment identifies 15,000 individuals and 2,000 wealth management taxpayers and expects a total revenue of HUF 800 billion over four years. This is roughly HUF 200 billion per year, an average of HUF 13 million per capita in annual taxes — a tax base of approximately HUF 1.3 billion at a 1% rate, or an average net wealth of approximately HUF 2.3 billion .

This calculation says more than political communication: the government's own model is not based on a few dozen super-rich, but on a broad ownership stratum in the 2–3 billion range: let's take a family house, a summer house, works of art, and a functioning business, and the jump to the one billion threshold could easily be realistic.

The formula that determines the value of family businesses

The vast majority of the tax base comes from corporate shares, and the proposal provides a formula tied to this: V = (ST + 2 × H) / 3, multiplied by the ownership percentage,

where ST is the equity of the last closed year (weight 1/3), and H is the average of the after-tax profit of the last three closed years, divided by a capitalization rate of 15% (weight 2/3).

This is the structure of the Swiss Praktikermethode . In practice, a 15% rate means that every 100 million forints of average after-tax profit increases the value of the company by approximately 444 million forints. Some examples: 1,200 million with equity and 240 million average profit is 1,467 million; the same with zero profit is 400 million; 3,000 million with equity and zero profit is 1,000 million; a start-up company founded with 200 million equity is 67 million forints.

The legal policy justification is defensible. After the 8/2010. (I. 28.) AB decision — in which the Constitutional Court stated that a clear, reliable and objective method is required for determining the market value — the legislator obviously wanted a tax base that could be calculated and operated with self-taxation. A fixed formula does not require that an individual company valuation be prepared for each family business. This is the greatest virtue of the proposal.

Three structural errors

Objectivity comes at a price: the value according to the formula and the real market value may diverge.

There is no lower limit for net asset value. In the Swiss model, which the proposal adopts almost verbatim, the result of the formula cannot be lower than the net asset value if operations were to continue — precisely so that a company with significant assets does not depreciate to almost zero simply because it does not generate a profit for a period of time. The Hungarian proposal does not have this limit, and the fact that this is not an accidental omission is shown by the rule for start-ups: there the yield value is explicitly zero, i.e. a company founded with 200 million forints of equity is worth 67 million forints. The submitted text has changed this point so that negative equity must be considered zero; this does not solve the structural problem.

The capitalization rate is uniform. A stable, asset-backed business and a volatile service company based on the personal work of the owner receive the same multiplier. The 15% itself is not strict in international comparison — the 9–10% typical in Swiss practice would give a higher company value —, so the problem is not the level, but the lack of variance.

There is no substantive counter-evidence. The point of Decision 8/2010. AB was not that the legislator should not use normative valuation, but that it should not unilaterally shift the risk of uncertainty to the taxpayer. The proposal provides ways out, but these primarily serve to exempt the taxpayer from the fine: the tax difference must still be paid. A solution would be if the taxpayer could prove with a documented, independent valuation that the formula value differs significantly — say, by more than 25% — from the real market value. In both directions: this would not only protect the taxpayer, but also the state's revenue if the formula underestimates.

Discounts and what's missing

The most important benefit is the threshold per taxpayer. In the case of married couples, the property contract is the primary decision; in the absence of this, they can jointly choose for registered assets whether the given asset should appear in the tax base of one of them or be divided 50–50%. In the case of a minor , the asset is generally included in the tax base of the parent, except for the inherited and the assets acquired from the child's own earnings. Taxpayers of linked asset management can only apply the threshold together, once. In addition: minority deduction (25% or 30%), zero return value for a start-up company in the first three years, inclusion of local tax and vehicle tax, inclusion of half of the valuation expert's fee up to 2 million forints per year, and payment deferral for 12 months, and 24 months in the case of residential real estate and company shares.

The list of shortcomings is at least as instructive. There is no exemption for government securities, TBSZ and NYESZ , and pension insurance is part of the tax base at its buy-back value. This is consistent with the “broad tax base, low rate” principle, but it is difficult to reconcile with the domestic system of self-care incentives.

The benefit of owning a residential property is also missing, and the tax burden maximum is missing: in Spain, the combined burden of personal income tax and wealth tax cannot exceed 60% of the income tax base. This would systematically address the situation when someone has a lot of wealth but a small income. The Hungarian proposal only provides for a fair payment deferral, which is not the same.

Here is the exit tax

The most important innovation is not in the wealth tax. The government submitted a tax package on the same day, which introduces the exit tax from January 1, 2027, by amending the Personal Income Tax Act.

The tax affects individuals who have been Hungarian residents for at least five of the previous ten tax years and cease to be Hungarian residents — provided that the assets of the person concerned (shares, securities, investment certificates, crypto assets, certain options, and TBSZ, NYESZ and insurance residual rights) together exceed HUF 500 million , or they have at least a 20% stake in a company worth at least HUF 250 million. The tax is 15% on unrealized exchange rate gains , based on the daily market value prior to the change of residence; the loss cannot be included. In the case of moving to an EU/EEA member state, there is an automatic, interest-free deferral, which typically lasts until the sale; in the case of moving to a third country, it must be paid immediately.

This significantly changes the balance of the move out. The previous draft only imposed one annual property tax on mid-year changes of residence; now the entire accumulated, unrealized gain is taxed.

What else changed when you submitted it?

Several planning loopholes have been closed: in the case of the minority deduction, the share of close relatives must be calculated , the concept of holding has become broader, and negative equity is zero. However, it is a relief that a simplified, equity-based valuation can be applied to companies with equity of up to 100 million forints ; in the case of the NAV's mass valuation model, the authority can only deviate from the parameters correctly provided by the taxpayer if it proves that the data is untrue. Appraisers are registered separately: a valuation below 70% of the fair market value will result in a fine of 100 thousand forints, and three such cases will lead to cancellation within 365 days.

What should you do now?

1. Asset inventory according to the logic of the proposal — not a general inventory, but one that follows the broad concept of asset elements, including options, insurance rights, receivables, foreign accounts, and crypto assets.

2. Trial calculation of the company's value. The formula is public, the reporting data is available; with a few hours of work, it can be said whether the family is below or above the threshold.

3. Arrange the documentation, even before the valuation date. If the tax base is based on self-declaration, the support for the valuation will be the subject of legal dispute. For example, an investment in the value of the property can only be validated with a receipt; normal maintenance does not count.

4. Liquidity plan. The tax returns annually and is payable in cash, while the value typically consists of a company and real estate. You have to think carefully about what will be the cover: dividends, portfolio restructuring, a bond portfolio adjusted to maturity or a security-backed (Lombard) loan. There is practically no lending practice for artworks in Hungary, although there is a demand for it.

5. Overview of residency and ownership structure — now with the exit tax in mind, and exclusively based on real economic content.

What we do not recommend: hasty restructuring. NAV can examine the proper exercise of rights retroactively, up to May 14, 2026 — the date of publication of the government resolution on wealth tax — and the taxpayer must substantiate subsequent transfers, restructurings, and unusual valuations with real economic reasons.