Changes in the VAT Return

Some from the older generation may still remember the storybook A Tale for Every Day, first published in 1978, which contained 366 stories (also taking leap years into account). There are also numerous changes related to VAT, even if there is not necessarily news for every single day. One such timely topic concerns the VAT return for 2026. The Hungarian Tax Authority (NAV) has already published on its website the VAT return form No. 2665 and the recapitulative statement form No. 26A60. In this newsletter, we report on the main information related to these.

VAT Return

Form 2665A:

• In 2025, a customs indirect representative’s statement regarding the assigned right to deduct VAT had to be completed in thousand forints until 30 September, and from 1 October in forints, in accordance with the new rules added to Section 129 (5) of the VAT Act. In 2026, the tax base and tax amounts must be entered in forints throughout the entire year in columns (c) and (d) of sheet 2665A-03. The tax amount entered in forints in the total line 33 (column d) of the last 2665A-03 sheet must match, rounded to thousand forints, the amount shown in column (a) of lines 70–71 on sheet 2665A-01-02.
• A new field has been added to column (b) of line 1 on sheet 2665A-04. This serves to indicate the reason for applying an interest calculation that differs from the general rules. The related guidance notes emphasize that, as a general rule, in the case of an increase in tax liability, the basis for the self-revision interest is the difference between the incorrectly reported earlier tax and the corrected tax established by the self-revision. However, due to certain exceptions, the interest calculation may deviate from this rule, in which case the reason must be indicated in the field “Reason for interest calculation differing from the general rule” on line 1 of sheet 2665A-04. The guidance describes the circumstances covered by the nine available codes.
• Form 2665A no longer includes the EUNY sheet. In previous VAT returns, this sheet was used—solely in cases of self-revision—to provide a statement regarding the reason for the self-revision, where the only reason was that the legal rule establishing the tax liability was unconstitutional or conflicted with a binding legal act of the European Union.
• From 1 October 2025, for gas sales between taxable dealers, the unit of measurement for reporting the gas quantity changed from cubic meters to MWh. Accordingly, columns (e) of sheets 2665A-07 and 2665A-08 no longer include m³ as a unit, only kg and MWh.

Form 2665M:

• On sheets 2665M-02 and 2665M-02-K, it is no longer only noted as a general reminder that data must be reported in forints— the word “forint” also appears directly in the fields for entering the tax base and tax amount.
• Regarding the fields marked “Optional to fill in” (f1–f4 on sheet 2665M-02 and h1–h4 on sheet 2665M-02-K), we highlight the following:
  As we have reported in previous newsletters:
  • Since 31 July 2025, parts of the recapitulative statement may optionally include separately the VAT amounts actually deducted from that date onwards.
  • In the recapitulative statements linked to returns for tax periods including 1 July 2026, it will become mandatory to report data on VAT actually deducted.
  • Meanwhile, according to NAV’s notice, the ÁNYK system will no longer be usable after 31 December 2026. For VAT returns, this currently means that taxable persons will have to switch to the eVAT (eÁFA) system, either via the web interface or through machine-to-machine (M2M) connection.

Given that point 15 of Annex 10 of the VAT Act exempts taxpayers using the eVAT system—whether via the web interface or M2M connection—from submitting the M sheets, the above developments would mean that a data reporting obligation would become mandatory for only half a year, after which it would no longer be required. This would force taxpayers to implement a development that would be usable for only six months.

It cannot be ruled out that the legislator and/or the tax authority will recognize this burden placed on taxpayers and either the reporting of actually deducted VAT on the M sheet will not become mandatory in the second half of 2026, or the ÁNYK system will remain usable even after 31 December 2026.

Recapitulative Statement:

There are no substantive changes to the data required on form 26A60 compared to form 25A60.

If you have further questions regarding the data content of VAT returns or the development of the returns, please feel free to contact our experts.