As of 2019, Hungary has introduced a new group taxation regime,
which allows for interesting planning opportunities.
According to the new rules, group taxation can be opted for by
at least two entities subject to corporate income tax in Hungary,
provided that (i) one of the entities directly or indirectly holds
at least 75% of the voting rights in the other entity; or (ii) the
same person directly or indirectly holds at least 75% of the voting
rights in each entity.
The tax base of the group consists of the positive tax bases of
its members. Each group member has to determine its tax base in
accordance with the corporate income tax rules. In contrast to the
current Hungarian tax legislation which does not allow a taxpayer
to utilize losses carried forward by another taxpayer, the negative
tax bases of group members may, subject to certain limitations, be
utilized to decrease the tax base of the tax group in the tax year
and the subsequent five years. Special rules
