Retail tax: intra-group aggregation requirement abolished

To facilitate access to European Union funds, Parliament - alongside numerous other legislative changes - also amended the Retail Tax Act. With effect from 31 July 2026, the tax-base aggregation rule for retail tax has been abolished. This rule previously required the turnover of associated enterprises to be taken into account on an aggregated basis when determining the base for the progressive tax.

What does this mean in practice? Retail tax is a progressive tax burden based on turnover (revenue). Its rate is 0% up to annual revenue of HUF 1 billion, while above HUF 150 billion it is already 4.5%. From now on, however, the progressive taxation must be calculated separately for each company, without group-level aggregation. If each store in a corporate group is operated by a different company, each store's revenue must be taxed separately, and each may therefore readily fall into a lower tax bracket. Companies currently taxed at a higher rate may therefore, in principle, have an opportunity to continue to be taxed at a lower rate after reorganising their activities. At the same time, they must continue to observe the requirement for the proper exercise of rights and the substance-over-form principle prescribed by tax law. A restructuring undertaken solely to reduce tax may be challengeable as a matter of principle.

If you have any questions regarding the above, please contact your usual contact at Crowe FST, or Balázs Földes, Tax Group Partner.