A technical guide to the Hungarian wealth tax bill (vagyonadó), article by article, with the choices to make before 31 December 2026 and the ITL Group advisory pathway.
In brief
Bill T/930 introduces, from 2026, an annual 1% tax on net wealth above HUF 1 billion (1.5% above HUF 100 billion). The first tax base is determined on the assets held on 31 December 2026; the return and payment are due by 31 August 2027.
The rate is simple, but the amount depends on technical choices: residence, the allocation of assets within the family and, above all, the valuation method for real estate and shareholdings. Many of these choices must be prepared before the reference date, and some can be made only once a year through joint declarations.
ITL Group supports business owners, families, investors and expats at every stage: review of the position, valuations, tax return and liquidity planning.
1. Legal framework and legislative process
Bill T/930 “A vagyonadóról” (On the wealth tax) was submitted to Parliament by the Government on 27 October 2026. The sponsoring minister is the Minister of Finance, András Kármán.
The text essentially confirms the draft put out for consultation by the Ministry of Finance on 6 October 2026. The intention to introduce the tax had been known since 14 May 2026, the date of Government Resolution 47/2026 (V. 14.).
| Part | Articles | Content |
|---|---|---|
| Principles and definitions | 1–5 | Completeness, no double counting, anti-avoidance, definitions |
| Taxpayers and tax liability | 6–12 | Taxpayers, tax base, allocation, tax treaties, rates and credits |
| Valuation of assets | 13–28 | Rules for each asset class; trusts and foundations |
| Procedure | 29–33 | Return, payment, instalments, audits, asset-holding structures |
| Reporting obligations | 34 | Data provided by companies to shareholders and to NAV |
| Final and transitional provisions | 35–39 | Entry into force on 15 December 2026, rules for 2026 |
| Annex 1 | – | Valuation formula for unlisted shareholdings |
| Annex 2 | – | Indexation of real-estate values |
The text may still change during the parliamentary debate. Registration procedures will be laid down in a ministerial decree (art. 37).
2. Taxpayers and residence (arts. 5–7)
Taxpayers are resident and non-resident individuals and resident and non-resident “asset-management structures”: Hungarian trusts (bizalmi vagyonkezelés), private foundations (magánalapítvány) and similar foreign structures (art. 6).
| Taxpayer | Taxable assets (art. 7) |
|---|---|
| Resident (individual or structure) | All assets, in Hungary and abroad |
| Non-resident (individual or structure) | Real estate located in Hungary and rights in rem over it; shares in companies governed by Hungarian law; shares in foreign companies holding Hungarian real estate (Hungarian real estate above 75% of total assets, also indirectly) |
Resident individual (art. 5, point 3). A person is resident if resident for personal income tax purposes (art. 3, point 2 of the PIT Act) and, in addition, a Hungarian citizen holding another citizenship, even without a domicile in Hungary. The following are not resident:
- foreign nationals seconded to Hungary by a foreign employer not registered in Hungary, for 5 years from the start of work (for those already seconded, from entry into force: art. 38);
- Hungarian citizens who, on 31 December, have been living permanently abroad for at least 10 years;
- third-country nationals holding a long-term residence permit who spend fewer than 183 days in Hungary in the year.
Resident structures. Structures governed by Hungarian law and foreign structures with their place of effective management in Hungary are resident. If a founder is resident in Hungary, the place of management is presumed to be in Hungary unless proven otherwise; the presumption also applies if a resident beneficiary in fact influences decisions. Formal approvals or signatures abroad are not enough to rebut it.
Change of residence. If residence ends during the year, the tax year runs from 1 January to the day before residence ends (art. 5, point 35). In our reading, the tax base is then determined on the assets held on that date, without pro-rata reduction.
3. Tax base, rates and credits (arts. 8–12)
The liability arises once a year, on the last day of the tax year, on the assets held on that date (art. 8). The tax base is the portion above HUF 1 billion of the difference between the calculated value of the assets and the deductible debts (art. 9).
Deductible debts. Only existing, documented debts arising from law, a final court judgment, a final administrative decision or a credit or loan agreement executed as a notarial deed or as a private document with full probative force. For non-residents, only debts directly linked to the taxable assets. The wealth tax itself is not deductible.
Exclusions (art. 9(3)–(5)). Personal effects and household furnishings are excluded, except:
- works of art, collections and jewellery with a unit value above HUF 3 million (collections are valued as a whole);
- vehicles, boats and aircraft worth more than HUF 10 million.
Assets used even partly in a business or professional activity are counted at their full value, with no thresholds.
Rates (art. 12(1)).
The tax formula (art. 12(1))
Tax = 1% × min(B; HUF 100 bn) + 1.5% × max(0; B − HUF 100 bn)
where B is the tax base in forints. The tax is rounded to the nearest thousand forints.
Tax reductions (art. 12(2)).
- 50% of the fees, VAT included, for appraisals and valuations made mandatory by the law, up to HUF 2 million a year in total; optional valuations do not qualify for the credit;
- local taxes (building and land tax, communal tax) and vehicle tax paid on the declared assets, and similar foreign taxes;
- a credit for foreign assets exempt under a tax treaty that allows progression.
Tax treaties (art. 11). They prevail only if they cover taxes on wealth. The example in the explanatory memorandum: Hungarian assets of HUF 3 billion plus exempt foreign assets of HUF 2 billion give a tax of HUF 40 million on the total, minus HUF 10 million attributable to the foreign assets, so HUF 30 million is payable.
4. Allocation of assets: family and structures (arts. 4, 10, 28, 33)
Every taxpayer is entitled to the HUF 1 billion threshold. The allocation rules prevent it from being multiplied by splitting wealth.
| Situation | Rule |
|---|---|
| Co-ownership | Each co-owner counts their share of the value of the whole asset (art. 10(1)) |
| Spouses | Separate taxpayers. A marital property agreement prevails; failing that, assets registered to one spouse are allocated to that spouse alone or split in half, at their choice, through identical declarations by both on the NAV form by 31 August. Without declarations they are split in half. Personal effects stay with the owner (art. 10(2)–(3)) |
| Minor children | Their assets are added to those of the parent exercising parental responsibility (half each if shared) and use that parent’s threshold. Assets inherited or earned by the child remain the child’s (art. 10(4)–(5)) |
| Adult children | Independent taxpayers with their own threshold |
| Transparent entities (civil-law partnerships, partnerships) | Assets and debts are allocated to the partners pro rata (art. 10(6)–(7)) |
| Trusts and foundations | Independent taxpayers, separate from founder, manager and beneficiaries; each asset is valued as if it belonged to an individual (art. 28) |
| Related structures | Same founder, or related or connected founders, also indirectly: a single HUF 1 billion threshold, to be shared through identical declarations; failing that, in order of establishment (art. 28(3)–(6)) |
Obligations of structures (art. 33). Structures must:
- register with NAV within 30 days (existing structures: by 14 January 2027), stating the governing law, place of effective management, representatives, all founders and those connected to other structures;
- appoint a principal representative and, if no one has a domicile in Hungary, a process agent;
- keep separate records;
- pay the tax out of the structure’s assets, never out of the manager’s personal assets.
Anti-avoidance (art. 4)
From 14 May 2026, NAV may check that every transaction involving wealth (gifts, transfers, new structures) is supported by real and demonstrable economic or personal reasons. Transactions designed solely to reduce the tax base are disregarded.
5. Valuation of shareholdings (arts. 15–18, annex 1)
Listed or regularly traded (art. 15(1)–(2)). The closing price on the last trading day is used; if it deviates by more than 10% from the volume-weighted average of the last 180 days, the average applies.
Unlisted: statutory formula (annex 1, I).
Unlisted shareholdings – statutory formula (annex 1)
V = (E + 2 × R) ÷ 3 × share
R = [(Pn + Pn-1 + Pn-2) ÷ 3] ÷ 0.15
E is the equity in the latest approved financial statements, P the net profit of the last three closed financial years, R the earnings value. If average profit is negative, R = 0; if E is negative, E = 0. The latest financial statements available at the time of filing apply: for 31 December 2026 this will probably be the 2026 statements, if approved in time.
| Case | Rule |
|---|---|
| Equity above HUF 500 million | Hidden reserves are added to equity: market value minus book value of real estate, shareholdings and long-term securities, net of deferred taxes (or 15% if not estimable), verified by an auditor. No auditor is needed if values calculated under the law are used |
| Holding companies | Shareholdings, securities, financial assets, cash, owner-occupied real estate and receivables from subsidiaries making up at least 90% of total assets: V = E × share, without R. Where consolidated accounts exist, consolidated data are used, net of minority interests |
| Equity up to HUF 100 million | Optionally, V = E × share (art. 15(9)) |
| Newly established companies | R = 0 in the year of establishment and the following two years, as long as equity stays below HUF 500 million and R does not exceed 25% of equity |
| Minority stake (below 50%, direct and indirect) | Discount of 25% (stake from 33%) or 30% (below 33%). Stakes of close relatives are aggregated |
| Dividends | Dividends approved or paid after the financial year-end reduce equity |
| Recent sale | After a sale of more than 10% to independent third parties, the price may be used for one year |
| Foreign companies | Country-specific capitalisation rate; without data on hidden reserves, an independent valuation is required |
Independent valuation (art. 15(4)–(7)). It is allowed if financial statements are missing, if the business has changed significantly or if the stake carries special rights or restrictions (shareholder agreements, transfer limits, options). Requirements:
- a valuer independent of the shareholder, the company and their direct and indirect shareholders;
- valuation revenue above HUF 250 million in each of the last three years, or above 25% of total revenue and at least HUF 50 million;
- at least two methods among income, market comparison and asset-based, with weights and reasoning.
Obligations of the company (art. 34). Hungarian companies with equity above HUF 500 million provide shareholders and NAV with hidden-reserve data within 30 days of approving the financial statements, if at least one shareholder requests it. They provide the valuer with data within 30 days of the request.
Other cases. Sole proprietorships (art. 16), professional firms, cooperatives and other entities (art. 17), and foreign real-estate companies held by non-residents (art. 18) have their own rules.
6. Valuation of real estate and other assets (arts. 13–14, 19–27)
Every value refers to 31 December; foreign-currency amounts are converted at the official MNB rate for that day. For assets without a specific rule, the ordinary market value applies (art. 13).
Real estate in Hungary: mandatory order (arts. 19, 21)
- Transaction value from the last 12 months between independent parties, without material changes to the property (a renovation costing at least 20% of the value counts as one).
- Indexed value of a transaction up to 10 years earlier: for homes the MNB price index (Budapest, cities by region, villages), for agricultural land KSH prices, for other real estate the annual KSH index; calculated with the NAV tool.
- NAV mass-valuation model for homes, holiday homes, building plots and agricultural land without buildings. If the data entered are correct, NAV cannot challenge the value (art. 31(4)).
- Appraisal by an independent expert listed in the NAV register.
An appraisal may be chosen instead of steps 2 and 3; instead of step 1 only exceptionally. A deviation of more than 20% must be justified in detail.
High-value properties (value of HUF 500 million or more). Only a court-registered real-estate valuation expert, using at least two methods among comparison, income and cost, with justified weights (art. 23).
Taxpayer protection (art. 31(2)–(3))
If the appraisal meets the legal requirements and the taxpayer has provided complete and truthful information, a higher value later set by NAV triggers no penalties or late-payment interest; only the tax difference is due. An appraiser who undervalues by more than 30% risks a fine and, after three fines in a year, removal from the register.
Real estate abroad (art. 20)
Purchase price (or value set by the local authority) plus improvements, uprated each year by 3% or by the country’s official price index, at the taxpayer’s choice. Without data, the official foreign value (cadastral or tax value) is used, then an appraisal. A voluntary appraisal is allowed only if it shows a lower value.
Other assets
| Asset | Value |
|---|---|
| Accounts and cash | Balance on 31 December, nominal value |
| Listed bonds | Average closing price of the last 20 trading days |
| Funds | Unit value (NAV) on 31 December |
| Receivables | Outstanding principal; the irrecoverable portion is excluded |
| Life insurance | Surrender value, attributed to the policyholder (pension insurance to the insured person) |
| Crypto-assets | Quantity × closing price on a platform with regular trading |
| Investment precious metals | Fine metal content × international reference price |
| Movable assets (cars, boats, art) | Purchase price from the last 12 months, then prices of comparable assets, then insured market value; or an appraisal |
| Usufruct and rights of use | Rules of the Duties Act (Itv. art. 72); the owner deducts the value of the right |
| Options | The higher of market value and intrinsic value; options linked to future performance and not exercisable are excluded |
7. Compliance, audits and instalments (arts. 29–34, 38–39)
Tax return (art. 29). The tax is self-assessed, declared and paid by 31 August of the following year, electronically only. A return is required only if tax is payable. For each asset the following must be stated:
- description, title and date of acquisition, identification data and share held;
- valuation method used, key data and calculated value;
- for debts, legal basis and amount, and the linked asset where required.
Documentation must be kept until the limitation period expires. Non-residents without a Hungarian tax number must register first. In the return, 5% of the tax can be allocated to the National Cooperation Fund (art. 35).
Inheritance (art. 29(2)–(5)). If the taxpayer dies after the liability arises, NAV assesses the tax ex officio. Inherited assets not yet handed over on the reference date are declared within eight months of the final order transferring the estate.
Audits (arts. 31–32). NAV cross-checks the declared data with its own records. Where discrepancies reduce the tax base, it requests clarification within 15 days (extendable once by 15). It opens an audit if the taxpayer does not reply, or if the discrepancy remains and amounts to at least HUF 500 million. If it proves that a transaction price was set low to avoid the tax, it uses the market value.
Payment in instalments (art. 30)
On application, NAV may grant deferral or instalments for 12 months, up to 24 in exceptional cases (in particular the family home or shareholdings), if a single payment would place a disproportionate burden on liquidity. The assessment considers whether at least 50% of the wealth consists of assets that do not generate cash. Automatic instalments are excluded.
Key dates
| Date | Obligation | Reference |
|---|---|---|
| 15 December 2026 | Entry into force | art. 36 |
| 31 December 2026 | Reference date: assets held on this day are counted | art. 8 |
| 14 January 2027 | Registration with NAV of existing trusts and foundations | art. 39(3) |
| 1 August 2027 | Hidden-reserve data for companies whose financial year differs from the calendar year | art. 38(2) |
| 31 August 2027 | Return and payment; joint declarations of spouses and sharing of the threshold among related structures | arts. 29, 10, 28 |
For 2026 only, the tax year runs from 15 to 31 December; for bonds, the average of prices from that date may be used instead of the 20-day average (art. 39).
8. The most exposed profiles
Based on our experience with Italian and international clients in Hungary, these are the cases that call for an analysis before 31 December 2026.
| Profile | Critical points | What to check |
|---|---|---|
| Business owner with a family company | Annex 1 formula, hidden reserves above HUF 500 million of equity, holding status, 2026 financial statements | Value of the stake with and without hidden reserves, minority discount, approved dividends, timing of approval of the financial statements |
| Family with wealth held in several names | Spouses, minor children, joint assets | Marital property agreement, joint declarations, assets of minors, documentation of gifts since 14 May 2026 |
| Trusts and private foundations | Residence of the structure, related structures, registration | Place of effective management, sharing of the threshold, registration by 14 January 2027, liquidity of the structure |
| Real-estate investor | Order of methods, high-value properties, deductible debts | NAV model or appraisal, properties of HUF 500 million and above, loans documented as the law requires |
| Dual citizens and residents abroad | Residence extended to dual citizens | Years lived abroad, foreign assets, tax treaty with the country of residence |
| Expats and seconded managers | 5-year exception, change of residence during the year | Type of contract (secondment or local employment), expiry date of the 5 years, departure date |
| Non-residents with assets in Hungary | Limited base, debts deductible only if linked | Hungarian real estate and companies, foreign companies holding Hungarian real estate |
In every case liquidity matters. As Alessandro Farina, Managing Director of ITL Group, points out, the issue is not the rate but whether the tax is sustainable for those whose wealth is in assets that do not generate cash. With HUF 5 billion of net wealth, the tax is HUF 40 million a year (about EUR 110,000), every year.
9. The ITL Group service
ITL Group offers a complete wealth-tax pathway, delivered by a single team that brings together tax, real-estate and business-valuation expertise.
The ITL Group pathway in 5 steps
1
Preliminary check-up (by December 2026)
- inventory of assets and debts at 31 December 2026
- review of the residence of the client and of their asset-holding structures
- estimate of the tax and of the liquidity needed
2
Valuations
- ITL Real Estate: real estate in the statutory order, comparison with the NAV model, appraisals for high-value properties
- ITL Consulting: shareholdings with the annex 1 formula, hidden reserves, holding status, minority discounts
3
Choices permitted by law
- the most suitable valuation method for each asset
- joint declarations of spouses and sharing of the threshold among related structures
- documentation of deductible debts and of the reasons for transactions made since 14 May 2026
4
Compliance with ITL Tax Advisor
- registration of trusts and foundations by 14 January 2027
- return and payment by 31 August 2027
- application for instalments, if needed
5
Annual update: the tax recurs every 31 December, and with it the review of values and choices.
Book a check-up
Write to Alessandro Farina, Managing Director, at a.farina@itlgroup.hu, or call (+36 1) 269 5679. More information at www.itlgroup.hu.
Source: Bill T/930 “A vagyonadóról”, submitted on 27 October 2026 (official text). The text may change during the parliamentary debate. This information is general in nature and does not replace personalised advice.
