BBJ: What’s new for 2025?
Károly Radnai, Andersen: One of the most significant changes affecting the tax system concerns the implementation of the global minimum tax; 2024 was the first year of its application, and 2025 will be the first year of tax payment. Companies falling under the rules are just starting to realize the impact and take it seriously. Finally, calculations and tax preparations have begun to assess whether they will be above or below the 15% minimum tax rate.
Another hot topic may be the EU’s new deforestation directive (EURD), which, from early 2026, will impose significant financial burdens on those trading with cocoa, coffee, soy, palm oil, wood, rubber, and cattle products (and their derivatives). Companies falling under the scope of these rules must implement secure procurement measures and meet regulatory requirements to avoid severe sanctions. Following the previously introduced EPR and CBAM regulations, the EUDR is the third wave of EU-level tax measures related to ESG.
Borbála Bodó, Grant Thornton: The global minimum tax continues to impact 2025. While filing for the 2024 tax year is due 18 months later, tax prepayments must be made by Nov. 20, 2025, requiring upfront tax calculations. Although reporting requirements have expanded, Hungary’s tax authority has not reflected these in the GLoBE form. Retail tax now applies to platform operators facilitating B2C sales (for example, marketplaces and apps), shifting tax liability from retailers to platforms. Also, simplified employment rules have tightened, now capping individuals’ employment under such contracts, not just employers.
Tamás Vékási, EY: One of the most critical challenges is the geopolitical tension, which puts pressure on multinational and Hungarian companies. A recent example is the trade restrictions and new tariffs announced by the United States. The tariffs and the looming global trade war will surely have a ripple effect that could disrupt global supply chains, landing costs, demand, and preferred trade routes in ways that would challenge even the best-prepared organizations.
Zsolt Srankó, KPMG: Digitalization and the use of AI are a priority for adoption in taxation. Taxpayers’ resources alone are not comparable to those of the tax authority, and outsourcing may become more critical.
BBJ: How prepared is the market to respond to these changes?
Borbála Bodó, Grant Thornton: Most stakeholders grasp the global minimum tax, but many overlook the prepayment deadline. Foreign platform operators have begun assessing compliance, yet even the most diligent struggle with unclear regulations and tight deadlines. The labor market seems largely unprepared for the new employment limitations.
Tamás Vékási, EY: A volatile geopolitical environment poses risks for every organization. While tariffs can disrupt supply chains, they also create opportunities for innovation and improvement. Flexibility, agile planning processes, and technology investments can all contribute to building resilience in the face of uncertainty.
Zsolt Srankó, KPMG: Businesses should prioritize their agenda to keep pace with the tax authority and strategically consider options for internal development or partner with third-party service providers to access the necessary technology and expertise. The market is gradually adapting to these changes, with many businesses already exploring outsourcing options to manage their tax functions more effectively, without overburdening their internal resources. The key will be to carefully manage the transition and mitigate associated risks, such as data security and compliance with tax regulations.
BBJ: Does Hungary follow a fairly tried and tested approach, or is it an outlier (either a pioneer or a laggard)?
Borbála Bodó, Grant Thornton Hungary: While the global minimum tax is an OECD directive, Hungary’s unique “prepayment” requirement stands out. Regarding the extension of the reporting form (GLoBE), we expect an obligation similarly detailed as in Belgium.
Tamás Vékási, EY: In areas like tax digitalization, data access and performing remote audits, we are emerging as pioneers, leading the way for other EU countries to follow. In general, Hungarian companies are well-positioned in terms of digitalization. However, there is no tested approach to coping with global supply chain challenges. Country policymakers should support businesses.
BBJ: What regulatory changes would help?
Borbála Bodó, Grant Thornton Hungary: Several EU countries (e.g., Austria, Germany, Slovakia) have modified social security coordination rules to ease cross-border remote work, allowing employees to work 50% from home without shifting their social security obligations. Hungary’s 25% threshold creates a heavy administrative burden, and alignment with peers would simplify cross-border employment. Additionally, Hungary’s frequent emergency-driven regulatory changes create legal uncertainty, underscoring the need for codifying lasting tax amendments directly into tax law.
Tamás Vékási, EY: In an unpredictable geopolitical landscape, providing a predictable regulatory environment for businesses is essential, minimizing periodic and one-off taxes. Further simplifying administrative processes and strengthening collaboration between the tax authorities and companies will foster an even more business-friendly environment.
BBJ: Anything else to add?
Károly Radnai, Andersen: Another wave of uncertainty is fueled by Donald Trump’s announcement on imposing new customs measures against the EU, among others. We are on the brink of an emerging trade war, the effects of which Hungary cannot escape. We do not yet know how big the waves of this issue will be, but it will likely impact the Hungarian economy and the tax system. Regarding the renegotiation of the U.S.-Hungarian tax treaty, although hopes are high among Hungarian government officials, we do not expect a new tax treaty to come into force in the next few years as the ratification process on the U.S. side will undoubtedly take a long time.
Tamás Vékási, EY: It’s crucial for businesses to embrace digital transformation proactively. By leveraging technology and fostering a culture of compliance, we can position Hungary as an EU leader in tax innovation.
Zsolt Srankó, KPMG: The government may focus on administrative cuts and concessions for the SME sector and individuals.
Taxation Market Talk Panel 2025
• Károly Radnai, managing partner, Andersen in Hungary
• Borbála Bodó, director of tax, Grant Thornton Hungary
• Tamás Vékási, country managing partner, EY Hungary, CESA Central Cluster Tax and Law Leader
• Zsolt Srankó, partner, Tax & Legal, KPMG.
This article was first published in the Budapest Business Journal print issue of February 21, 2025.
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