Traded equity interests and debt securities – based on the draft

Investment classification would determine the method

The draft would not apply one stock-market valuation rule to every investment. Section 12(1)–(2) would govern corporate equity interests, Section 21(2)–(3) specified debt securities, and Section 21(4) collective investment securities. Exchange trading alone would therefore determine neither the relevant period nor whether closing prices, an average or net asset value applied.

Point 34 of Section 2 would exclude collective investment securities from corporate equity interests while referring to accounting legislation for ownership investments. The external statute's unstated details could not be reconstructed from the draft. Section 5 would determine holdings by year-end asset ownership, but valuation prices could derive from earlier trading days or other published data.

Equity interests: closing price and the ten-per-cent switch

Section 12(1) would start with the closing price on the reference year's final trading day for exchange-listed corporate equity interests. If it differed by more than ten per cent from the volume-weighted average over the year's final thirty days, valuation using that thirty-day average would replace it. The wording would address the size of the difference generally, not only upward deviations.

Section 12(2) would apply the same structure to corporate equity interests regularly traded outside regulated markets or exchanges. A difference of exactly ten per cent would not satisfy the greater-than-ten-per-cent condition. This would not be a free choice of the more favourable closing price or average: the specified deviation would trigger the switch. Nor would the thirty-day period become twenty trading days.

Listed debt: an average over twenty trading days

Section 21(2) would cover listed debt securities that were neither corporate equity interests nor collective investment securities. Their valuation would use the arithmetic average of closing prices over the twenty trading days preceding the reference year's final day. There would be no equity-style ten-per-cent test, and the final closing price would not be the general starting point. The two methods would not be interchangeable.

If some of those twenty trading days lacked a closing price, Section 21(2) would require the arithmetic average of available closing prices. Missing days would not need invented quotations. The rule would narrow the available dataset rather than reduce value by the number of missing observations. Unlike the volume-weighted equity comparison, the draft would expressly prescribe an arithmetic average here.

Off-exchange trading and nominal value

Section 21(3) would also use twenty trading days for unlisted debt securities regularly traded outside regulated markets. Prices would need publication by a commercial financial-market data provider independent of both taxpayer and issuer. The arithmetic average of qualifying available market prices within that window would govern, rather than any participant's unrestricted indication of value.

Without qualifying prices, Section 21(3) would refer to subsection (5), which would use nominal value. Subsection (5) would also apply directly to debt securities neither listed nor regularly traded. Nominal value would therefore be the primary rule for one category and a data-dependent fallback for another. It would not become a freely selectable alternative to averaging whenever debt securities had market prices.

Collective investments: net asset value first

Section 21(4) would multiply holdings in each series by published year-end net asset value per security. If year-end data were unavailable, the latest preceding published net asset value would follow. This would establish a separate hierarchy: exchange trading would not itself displace an available qualifying net asset value.

Only without such value, and where regular regulated-market or off-market trading existed, would Section 21(2) or (3) apply correspondingly. If that also failed, ordinary market value would govern. The draft would therefore create successive fallback stages. The equity rule linking final closing price to a ten-per-cent deviation could not simply be transferred to collective investment securities, because it would address a different asset category.

Separate elections for the proposed first year

Section 32 would propose commencement on 15 December 2026; this would not be a confirmed obligation or enacted date. Section 35(1) would define the first reference year as running from commencement to the liability date. Subsection (2) would allow the ordinary Section 12 equity valuation or a transitional method comparing the closing price with the volume-weighted average across that shortened year's days.

Section 35(3) would similarly allow relevant debt securities to use the ordinary rule or the arithmetic average of prices available in the shortened reference year. Listed securities would use closing prices; regularly traded off-exchange securities would use qualifying independent-provider market prices. Without the latter, Section 21(5) would still apply. This would be a proposed 2026 choice between specified windows and methods, not unrestricted price selection.

Currency, tax base and supporting price data

For foreign-currency values, Section 11 would separately require conversion into forints. The MNB rate published for the year's final day would govern, or the latest preceding rate if unavailable. Multiple same-day publications would require the last rate; unlisted currencies would use the MNB's euro-denominated quotation as the basis. Security prices and currency exchange rates would therefore perform different functions.

The HUF 1 billion net threshold in Section 6 would concern the aggregate wealth tax base, not a valuation threshold for an individual securities series. Section 9(1)'s HUF 100 billion band would apply to that tax base, with one and one-and-a-half per cent rates. Section 25(7)–(8) would require disclosure of method, material data and value, plus record retention. The pricing window and source would consequently form part of the valuation's substantiation.

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