Did you know that, as of 1 January, higher fines apply and there is a new discount for early payment of assessed tax?

Increase in penalty rates

The aim of the legislative change was to strengthen not only the punitive but, above all, the preventive effect of fines. Consequently, both the lower and upper limits of fines for basic breaches of obligations under Section 155(1)(a) to (e) of the Tax Code are being increased.

The amendment raises the lower limit of these fines to a uniform EUR 100, instead of the previous EUR 30 or EUR 60.

The following maximum fine amounts will now apply (the original limits are shown in brackets):

• failure to file a tax return within the statutory deadline: a fine of up to EUR 30,000 (EUR 16,000), or up to EUR 60,000 (EUR 32,000) upon a request from the tax administrator,
• failure to comply with the registration obligation: up to EUR 30,000 (EUR 20,000),
• failure to comply with a reporting obligation, an obligation imposed by a decision or any other non-monetary obligation (including, for example, failure to submit transfer pricing documentation): up to EUR 10,000 (EUR 3,000).

The new rates will apply only to infringements occurring after 31 December 2025. Thus, if the offence was committed in 2025, the fine will be imposed according to the original limits, even if the decision is issued in 2026.

The legislation thus responds to the long-standing need to make the timely and proper fulfilment of obligations more attractive.

New relief for early payment of assessed tax

A key change for taxpayers is the amendment to Section 155(17) of the Tax Code, which allows for a reduction in the fine in the event of prompt payment of the additional tax.

How it works:

If a taxpayer pays, within 15 days of receiving the decision from the assessment proceedings:

• the additional tax assessed,
• or any other obligation imposed in the decision,

the penalty under Section 155(1)(f) will be imposed at two-thirds of the standard rate.

This is a new form of ‘early payment’ which can bring significant financial savings to businesses.

This mechanism for reducing fines applies exclusively to fines imposed under Section 155(1)(f), i.e. to penalties resulting from the outcome of the assessment proceedings.

This rule will apply for the first time to decisions served after 31 December 2025.

Example

On 5 February 2026, the taxpayer receives a decision imposing an additional tax assessment of EUR 2,000,000. We assume that the decision will become final on 25 July 2026.

The tax will be paid within the standard payment period, i.e. within 15 days of the decision becoming final (10 August 2026). In this case, the penalty on the additional tax assessed would amount to EUR 900,000.

However, if the taxpayer pays the tax assessed by the decision within 15 days of its delivery, i.e. by 20 February 2026, the penalty will be reduced to EUR 600,000.

It is important to emphasise that the final amount of the penalty under Section 155(1)(f) depends on several variables, in particular the amount of the additional tax, the ECB interest rate and the length of the period for which the penalty is calculated. In certain extreme cases, where the application of a double taxation agreement extends the point at which the tax liability ceases under Section 155(1)(f), the resulting fine may approach the amount of the additional tax itself. For higher additional tax assessments, the savings can be significant, amounting in some cases to tens or even hundreds of thousands of euros.

At the same time, early payment of the additional tax does not preclude the right to lodge an appeal. If the appeal is successful, the amount may be refunded to the taxpayer together with interest.