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Geopolitical tensions are redrawing global power lines, supply chains are being tested, and tax and trade frameworks are evolving at historic speed, while exponential technologies, especially AI, are triggering a profound leap in intelligence. In such an environment, resilience and strategic foresight have become as critical as growth itself.
For tax and finance leaders, this shift is especially visible. Their teams sit at the intersection of regulation, business strategy and data. As a result, transformation can no longer be something that happens every few years; it must be continuous. The tax function of the future adapts quickly, relies on high-quality data, and provides clear, timely insights that help leadership respond decisively.
Amid this volatility, compliance remains the most pressing priority. At the moment, three issues dominate the agenda for Hungarian CFOs and tax directors.
The rollout of the global minimum tax introduces significant compliance demands, but recent changes also create new opportunities to reduce exposure and simplify the work involved. These include:
• Substance-based tax credit safe harbors, which protect certain incentives from being neutralized.
• The extension of the transitional country-by-country reporting safe harbor to 2027, giving companies more time under simplified rules.
• A simplified effective tax rate safe harbor, reducing top-up taxes in lower-risk jurisdictions.
• A new side-by-side/unreimbursed partnership expenses safe harbor from 2026 can significantly reduce exposure to the income inclusion rule and the undertaxed profits rule.
For many groups, these tools mean fewer detailed calculations, fewer unexpected top-up taxes, and more predictable planning. For CFOs, they offer real choices in how to manage the organization’s effective tax rate as the GMT regime enters its next phase.
Hungary’s updated transfer pricing rules mark one of the most significant changes in recent years. On the one hand, what used to be considered “best practice” is now mandatory. Companies must apply stricter local benchmarking, prepare deeper functional and development, enhancement, maintenance, protection, and exploitation analyses, justify the benefits of intragroup services, and submit more detailed documentation.
The implication is clear: audit risk is increasing, and companies need stronger evidence to defend their positions. This is particularly relevant for multinationals with service fees, intellectual property arrangements, or centralized functions. The companies that prepare now will be far better positioned in future audits.
With ongoing supply chain pressures, customs suspensions, and tariff quotas, these remain powerful cost-saving opportunities for manufacturers relying on non-EU raw materials. These mechanisms can reduce or eliminate duty payments for up to five years, improving both competitiveness and liquidity.
In 2026, companies face two key deadlines:
• Feb. 28 for suspensions effective Jan. 1, 2027
• Aug. 31 for suspensions effective July 1, 2027
The second window is especially important, yet often overlooked. With the detailed justification required at the EU level, companies should begin preparing well ahead of these dates.
Given all that, it’s clear that tax and finance teams can no longer rely on familiar routines. They need better, more structured data, systems ready for automation and AI, and teams equipped to interpret new rules quickly and accurately. The goal is simple: understand what is changing, prepare early, and make decisions based on facts, not surprises.
This article was first published in the Budapest Business Journal print issue of February 27, 2026.
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