Opting for group corporate taxation can be an effective move for companies aiming to simplify compliance, share losses, and benefit from exemptions from transfer pricing rules within the corporate tax system. Applications must be filed between 1–20 November each year.
Who Can Join a Group?
Eligible members include:
- Hungarian tax residents,
- with the same balance sheet date,
- using identical accounting standards,
- linked by at least 75% voting rights,
- and not part of another tax group.
How and When to Apply
To form or join a group, the companies must submit a joint written request to the tax authority by 20 November.
This is a non-extendable deadline — late submissions are invalid.
If approved, the group status becomes effective from 1 January 2026.
The same timeline applies for joining an existing group.
Key Advantages
- Transfer Pricing Exemption: intra-group transactions are not subject to market pricing or documentation requirements under corporate tax.
- Loss Sharing: tax losses can be utilized at group level, even in the same year they arise.
- Preservation of Tax Credits: previously claimed benefits remain available at individual member level if conditions are met.
Practical Considerations
- New filing process: one consolidated corporate tax return is required, so internal compliance must be adjusted.
- Mid-year exit: if a company leaves the group during the year, it is treated as an individual taxpayer retroactively from the start of that year.
- Advance tax payments: members leaving the group must recalculate their advances individually, which may increase obligations.
- Interest limitation applies at group level: the HUF 939.81 million threshold applies collectively.
- Joint liability: all members remain jointly responsible for tax debts incurred during the group period.
Summary
Group corporate taxation offers strategic advantages for companies operating under common ownership. While setup requires careful preparation, the potential tax relief and reduced transfer pricing obligations can deliver substantial financial and administrative savings.
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