Self-assessment, return data and record retention – based on the draft

Self-assessment and the boundary of annual filing

Under section 25(1), taxpayers would assess, declare and pay tax annually using their final-day asset position. The proposed general deadline would be 31 August of the following year. However, a return would be required only where wealth tax became payable for that year; the provision would not establish universal nil wealth-tax returns.

Section 25(5)–(6) would require electronic administration for individuals and asset-management taxpayers alike. The tax base and tax would be determined in forints, with tax declared and paid rounded to the nearest thousand forints. Filing would use the authority’s prescribed form, although the draft would not supply its completed field structure.

The valuation trail would accompany the figures

Section 25(7) would require taxpayer identifiers and, for every included asset, its description, acquisition basis, identifying data, ownership share and calculated value. Acquisition dates would be needed where relevant to valuation. Each asset’s method and essential inputs would also appear, rather than only an aggregate wealth figure.

The same provision would require debt amounts and legal bases, identifying the related asset where direct connection was a deduction condition. Tax reductions would need descriptions, amounts and supporting data. Information establishing asset-management status and residence, representative details and, where applicable, domestic service arrangements would form additional reporting categories.

Retention and the separate inheritance timetable

Section 25(8) would retain records substantiating return data, valuations, debts and reductions until the assessment right became time-barred, with production on request. This would not prescribe one numerically fixed retention period for every case. Section 25(2)–(3) would introduce separate assessment and limitation commencement rules after death where the taxpayer had not completed all general obligations.

The authority would then assess tax within ninety days after the estate-transfer order became final. Section 25(4) would give an heir until the end of the eighth month after finality for inherited assets not yet transferred. Liability existing without the inheritance would require self-revision without the referenced Taxation Act’s self-revision consequences; otherwise assessment, filing and payment would occur then.

Clarification could precede an audit

Section 28 would address discrepancies between return data and information held or officially known by the authority that reduced the tax base. Identifying the discrepancies, the authority would allow fifteen days for clarification. A substantiated request submitted before expiry could secure one extension of up to fifteen days where an unavoidable external cause prevented compliance.

Section 28(4) would distinguish two audit triggers. Failure to respond would itself trigger an audit. Where a statement was submitted but the discrepancy remained unresolved, the prescribed audit would require a tax-base reduction of at least HUF 500 million. This procedural threshold would differ from the equally sized equity and high-value-property valuation thresholds.

Asset-management representation and registration

Under section 29(2)–(7), the person entitled under the governing law to represent the taxpayer, or otherwise manage its assets, would act. Multiple authorised persons would require a primary representative; until notification, any could act. New Hungarian-law formation, moving effective management to Hungary, or a foreign taxpayer’s first acquisition of an in-scope asset would trigger thirty-day notification. Specified circumstances recurring after cessation would require renewed notification.

Section 29 would require registration without an existing tax number, or continued use of an existing number. Information would cover governing law, foreign identifiers, management location, representatives, record location and settlor connections. If no authorised person had a Hungarian address or registered office, a domestic service agent would be required. These notifications would remain distinct from annual filing.

Separate records and company-supplied information

Section 29(8), (10)–(13) would require separate records and thirty-day notification of specified changes. A tax number would be deleted on cessation only if unnecessary for other taxes. Payment would come from segregated assets, with the representative ensuring funds were available. Enforcement would reach those assets, not the manager’s separate personal property.

Under section 30, a domestic company with equity exceeding HUF 500 million would communicate reviewed hidden-reserve data to ownership-right holders and the authority within thirty days after approving its accounts. Qualifying foreign-company information could also be used. A domestic company would provide valuation information within thirty days of the valuer’s request, with Annex 1, points IV(b)–(c), supplying the related valuation framework.

Commencement and transition would remain proposed

Section 32 would propose commencement on 15 December 2026, while section 33 would authorise ministerial notification and recordkeeping rules. Under section 34(1), the five-year period for qualifying non-Hungarian citizens already working through posting, assignment or agency arrangements for the specified foreign employer would run from commencement. This would not create a general transitional exemption for all foreigners.

Section 34(2) would set the relevant reporting deadline for previously approved latest non-calendar-year accounts thirty days before the proposed 31 August 2027 date. Section 35 would establish a short first tax year, optional first-year price periods for specified shares and debt securities, and thirty-day notification for existing affected asset-management taxpayers. Publication of the draft alone would not make any of these obligations effective.

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