Hungary’s tax penalty consequences of non-compliance with tax requirements are governed by the Act on Rules of Taxation.

The law outlines a range of sanctions for non-compliance, including tax penalties, default penalties, late payment interest and self-revision fees. This blog will provide an overview of each sanction and summarise recent changes in this area.

Types of sanctions in Hungary for non-compliance

In Hungary, there are four types of payable sanctions for not complying with tax rules. While most of these sanctions are imposed by the Tax Authority, the self-revision fee is calculated and settled through self-declaration.

Tax penalty

A tax penalty is imposed as a result of an audit when the Tax Authority identifies a tax shortfall during an inspection. The standard rate is 50% of the unpaid tax, but it can increase to 200% in some cases.

Default fine

A default fine is a sanction that the tax authority may apply in case of a breach or failure to comply with tax obligations specified in legislation regarding taxes and budgetary subsidies. Most default fines are determined as fixed fees rather than a percentage. The law determines the maximum amount of this fine. The Tax Authority has the discretional right to levy it in the maximum amount, decrease it, or void it.

The amount that the Tax Authority can levy depends on the type of non-compliance and the taxpayer’s status, i.e., whether it is an entity or an individual taxpayer. For example, a default penalty can be levied for missed or late submission of a tax return.

Late Payment Interest (LPI)

LPI is charged when tax liabilities are not paid on time. The interest is calculated daily, and the rate is based on the central bank’s base rate plus five percentage points divided by 365. The Tax Office determines and assesses the amount of LPI.

Self-Revision Fee (SRF)

A Self-Revision Fee (SRF) applies when taxpayers voluntarily amend their tax returns to report a higher amount than initially declared. The SRF is calculated at a rate equivalent to the prime rate. In cases where the same return is revised multiple times, the applicable rate is increased by 50%.

The SRF must be calculated and self-declared simultaneously with the revised tax liability.

The severity of sanctions and applicable settlement rules vary based on the so-called qualification of the taxpayers. Taxpayers are categorised into three groups: Reliable, Neutral and Risky. Reliable taxpayers benefit from more lenient treatment, including reduced default penalties, whereas risky taxpayers are subject to stricter sanctions. For neutral taxpayers, standard penalty levels apply by default.

Changes to Hungary’s tax penalty regime

Recent changes to Hungary’s tax penalty regime include the following.

Increase in default fine

The Hungarian government doubled certain penalty amounts from 1 August 2024:

Late Payment Interest (LPI) changes

Effective from 1 January 2025, there were changes in:

  1. Calculation method
    The payable LPI is calculated monthly. Previously, it was annually.
  2. Payment date
    Previously, the due date was 15th November of the following year.
    Based on the new rules for 2024, the LPI was payable by 31 March 2025. For the months of January to March, LPI is assessed in April and is payable by 22 April (as 20 April 2025 is a public holiday). From April 2025 onwards, LPI is levied and accounted for monthly on the taxpayers’ tax accounts and payable by the 20th of the following month.
  3. Rounding rules
    Late payment interest should be paid without rounding in HUF.
  4. Notification
    The Tax Office will not send notifications going forward on the amount of the payable LPI, although one will still be sent once the payment threshold has been reached. LPI will be booked on the tax account, and it should be settled monthly without notification. As a transitional rule, the notifications were sent out by the Tax Office for 2024.

Despite the change in the calculation method, no changes were made regarding the threshold under which LPI is not payable. This amount remained HUF 5,000 annually.

The Hungarian Tax Office issued a notification about the changes in LPI settlement on 11 April 2025 and published the corresponding guidance on its website on 3 February 2025.

Take Action

For further information about tax compliance in Hungary and beyond, contact Sovos’ team of experts today.

In a previous blog, we provided an overview of the current and proposed natural disaster-related measurements in some European countries and Australia. In this blog, we will focus on the possible EU-level solution proposed by the European Central Bank (ECB) and the European Insurance and Occupational Pensions Authority (EIOPA) in their latest discussion paper, issued in December 2024.

The proposal, as was also in the case of their discussion paper from April 2023, focuses on the growing “insurance protection gap” in Europe. It highlights that Europe is the fastest-warming continent in the world. If we look back at only the last six months, there were at least three severe climate-related catastrophes in Europe: Portugal wildfires and the Spanish and the Czech Republic Floods.

Among other significant economic consequences of the increasing frequency and severity of natural catastrophes, we need to highlight the impact of these events on insurance businesses and indirectly on the taxation of the insurance premium amounts.

The paper summarises 12 existing national natural catastrophe insurance schemes which we are going to brief in our blog series – adding the current tax treatment of these schemes. In this blog, we provide an overview of the EU-level solutions as proposed by the paper and a summary of the approaches followed by the EU countries.

Proposal for the possible EU-level solution

A two-pillar solution was included in the referenced document. The two pillars are:

Both of these pillars could potentially affect the amount of tax payable by the insurance companies on the collected premium amounts. The first pillar might indirectly increase the tax amount levied on the reinsured premium amount, such as in the case of France CCR (Caisse Centrale de Réassurance), where IPT (and contributions to the Major Risk Prevention Fund) is due on the CATNAT premium. The second pillar may trigger newly introduced contributions that might be levied on the insurance premium amounts.

Summary of the national level approaches

The current national schemes aim to broaden insurance coverage. Some countries, like Italy most recently, make certain natural catastrophe risks such as earthquakes, floods and landslides compulsory to be insured by either or both entities or individuals.

In other cases, compulsory reinsurance involving public-private sector coordination exists. The most well-known reinsurance system exists in France, the so-called CCR. However, there is a reinsurance system in Iceland, where insurers collect CATNAT premium amounts and pay them towards NTI (Icelandic Natural Disaster Insurance).

It remains to be seen the extent to which the proposals are acted upon and the impact that they may have on premium taxation regimes in the EU. As it is such a significant topic in insurance currently, Sovos will be keeping a close eye on developments in this area.

In Italy, the insurance premium tax (IPT) code (which is being revised as of the date of this blog’s publication) and various other laws and regulations include provisions for taxes/contributions on motor hull and motor liability insurance policies.

This article covers all you need to know about this specific indirect tax in the country.

As with our dedicated overviews of the taxation of motor insurance policies in Spain, Norway and Austria, this blog will focus on the specifics in Italy. We also have a blog covering the taxation of motor insurance policies across Europe.

Which taxes are payable concerning motor insurance policies in Italy?

In Italy, there are four types of charges payable on motor insurance policies:

How are the taxes calculated for motor insurance policies in Italy?

Whilst motor insurance policies can include various coverages as add-ons, this blog’s main focus is on motor hull and motor liability.

  1. Motor Hull (Class 3)

Calculating taxes on land vehicles, i.e., motor hulls (Class 3), is simple. There is only IPT at 12.5% and CONSAP at 1%.

The taxable premium is the basis of these taxes. Both taxes are declared in the annual IPT return and payable monthly.

  1. Motor Liability (Class 10)

The taxation of insurance policies against civil liability arising from the circulation of motor vehicles is more complex.

The IPT rate (so called Responsabilità Civile Auto or RCA tax) is determined on a provincial level. Legislative Decree 6 May 2011, No. 68 quotes that the rate of the RCA tax is equal to 12.5%. However, this can be increased or decreased by the province or metropolitan city by a maximum of 3.5%. That is why RCA tax rates are sometimes referred to as a tax with a rate ranging from 9-16%.

In Italy, there are 20 regions, each with one or more autonomous provinces or cities. To complicate matters further, the province or city can modify the tax rates within the tax year.

CONSAP does not apply on motor liability policies, however EMER is at a rate of 10.5% with an additional 2.5% required for RAVF.

RCA and EMER are declared in the annual IPT return, and payments are due monthly.

Although RAVF is also declared annually, the declaration process differs, and there is also a prepayment obligation. The actual amount of RAVF depends on the management fee set annually by the Italian insurance supervisory body (IVASS) – the percentage of which is published during November for the next year.

As previously stated, IPT/RCA regulations are undergoing major renewal (during 2024). The legislation governing the tax provisions on private insurance and life annuities (Law 29 October 1961, No. 1216) is part of the Italian Government`s tax reform initiatives.

According to the available draft legislation, the IPT law will be divided into three parts:

The government extended the deadline for enactment of the new regulation to the end of 2025.

What vehicles are exempt from tax in Italy?

There are not many exemptions available for IPT/RCA tax, nor for CONSAP, EMER and RAVF. However, cars registered in Italy to NATO Allied Force benefit from an exemption from IPT/RCA.

If you still have questions about the taxation of motor insurance policies or IPT in Italy, speak to our experts.

In Austria, the insurance premium tax law regulates the indirect tax that applies to elements of coverage under a motor insurance policy. This blog details everything you need to know about this particular indirect tax in the country.

As with our dedicated overviews of the taxation of motor insurance policies in Spain and Norway, this blog will focus on the specifics in Austria. We also have a blog covering the taxation of motor insurance policies across Europe.

Which taxes are payable concerning motor insurance policies in Austria?

In Austria, Vehicle Insurance Tax (VIT), or the so-called motor-related insurance tax, is payable in relation to:

VIT is payable in addition to the 11% insurance premium tax (IPT).

How is VIT calculated for motor insurance policies in Austria?

The calculation of VIT is complex. The tax is determined by the type of vehicle, the engine capacity/displacement and CO2 emissions for motorbikes, the performance of the combustion engine and the emission in grams per kilometer for passenger automobiles and the power of the combustion engine for all other engine types.

The date of registration is another item to consider when calculating the amount of VIT. The computation for automobiles registered before 1 October 2020 is different, however.

The following rates are effective for passenger cars registered after 1 October 2020 are as follows:

In 2020, the first component, power, was lowered by 65 Kwatt, while the second component, emission, was reduced by 115 grams per kilometre. Since 2021, the deduction has been lowered annually. Every year, the first component is reduced by one and the second by three. As a result, in 2024, the deductions are 61 Kwatt and 103 grams per kilometre.

To complicate this further, the aforementioned calculation only applies to M1 passenger cars whose CO2 emissions were established using the WLTP (Worldwide Harmonised Light Vehicle) test method. If this process is not followed, the calculation will be different.

Special rates apply to motorhomes, motorcyclists and other multi-track motor vehicles.

The computed amount is due monthly. Prior to 2020, the regularity of the payment was another aspect to consider in the computation.

What vehicles are exempt from tax in Austria?

First and foremost, VIT is required on motor vehicles weighing up to 3.5 tonnes. If the vehicle’s weight exceeds this limit, another type of tax – motor vehicle tax – is due.

The exemptions in Austria follow the usual considerations mentioned in our blog on taxation of motor insurance policies across Europe. Exemptions are dependent on:

Read our IPT Guide to learn more about Insurance Premium Tax compliance.

Take Action

If you still have questions about the taxation of motor insurance policies or IPT in Austria, speak to our experts.

Norway has an indirect tax that applies to elements of coverage under a motor insurance policy. This blog details everything you need to know about it.

As with our dedicated Spain IPT overview, this blog will focus on the specifics in Norway. We also have a blog covering the taxation of motor insurance policies across Europe.

 

Which taxes are payable in relation to motor insurance policies in Norway?

In 2018, Norway replaced the collection of traffic insurance tax with a new fee known as the Traffic Insurance Fee (TRIF). This fee is collected by the insurance companies on behalf of the Norwegian State, together with the premium for third-party motor liability insurance coverage.

The annual insurance tax needed significant administration. As such, implementing a new tax scheme on mandatory automobile third-party liability insurance policies aimed to streamline and speed up tax and excise administration. With the new approach, insurance companies must invoice TRIF together with the premium amount sent to registered vehicle owners. The fee is clearly stated on the invoice in a distinct line aptly named “Traffic Insurance Fee”.

 

How is TRIF on motor insurance policies calculated in Norway?

In Norway, the TRIF is charged for all registered cars that weigh under 7,500 kg. The Norwegian Tax Office collects the so-called weight-year tax on heavier vehicles, in which the TRIF is not due.

Norway charges the fee for insurance contracts on compulsory third-party liability insurance regarding motor vehicles registered domestically. The fee also applies to the sum received by the Norwegian Motor Insurers’ Bureau for uninsured motor vehicles or when the new owner has not taken out insurance for the motor vehicle.

There is no insurance premium tax on insurance policies covering Class 3 policies.

As stated above, insurance companies collect TRIF at the same time as the premium, so the fee is distributed in accordance with the frequency of premium payment. This can be monthly, quarterly, semi-annually or annually.

TRIF is a daily fee based on the type and usage of the vehicle. Vehicles are classified into five classes, from a) to f).

The new rates take effect on 1 March each year. This means that if the policy is issued or renewed on or after this date, the new rates will apply. The rates for 2024 range from NOK 0.37 (approx. EUR 0.032) for group e) to NOK 9.11 (approx. EUR 0.80) for group b).

 

What vehicles are exempt from tax in Norway?

Exemptions from TRIF occur based on the car’s usage or the owner. For example, motor vehicles registered at the Nordic Investment Bank that are used for official bank operations are exempt from TRIF. Vehicles registered at NATO or NATO headquarters, forces or personnel, as defined by international agreements, are also excluded. The exemption also applies to stolen cars.

The Ministry has the authority to issue regulations for implementation, delimitation and exemption criteria.

It is also worth mentioning that if liability insurance is not compulsory to take out, for example, in the case of the Norwegian state, municipalities or local institutions, the person responsible for the motor vehicle will be considered “self-insured”. In these circumstances, TRIF is not due.

Read our IPT Guide to learn more about Insurance Premium Tax compliance.

Have questions about the taxation of motor insurance policies or IPT in Norway? Speak to our experts.

Monaco is one of many countries with Insurance Premium Tax (IPT) requirements, specifically the Special Annual Tax and Fire Brigade Tax. This blog provides an overview of IPT in Monaco to help insurance companies remain compliant.

 

What kind of taxes are applicable in Monaco on insurance premium amounts?

In Monaco, there are two types of taxes that apply to premium amounts received by insurance companies. These taxes apply to domestic as well as foreign insurance companies who write business in Monaco, whether or not they have a branch office there.

It is necessary to highlight that Monaco is not a member of the EU/EEA. As a result, the Location of Risk provisions outlined in Directive 2009/138/EC, often referenced as the Solvency II Directive, do not apply. Therefore, determining whether a premium amount triggers Monegasque insurance premium tax or not requires understanding the local territorial rules.

The Monegasque insurance premium taxes are:

 

What are the tax rates in Monaco?

SAT rates vary based on the risks covered. The lowest rate is 0.20% for policies covering export credit risks, while the highest rate is 25% for policies covering property risks with a fire element. Most taxable insurance is subject to a 7% rate.

There are various exemptions from SAT, such as life insurance and related contracts, reinsurance, and risks located outside of Monaco.

There is a fixed rate of 9% for Fire Brigade Tax.

 

What is the basis of SAT and FBT calculation in Monaco?

The taxable premium is the taxable basis for both SAT and FBT. It is defined as the sum stipulated for the benefit of the insurer, including any extra fees or charges paid directly or indirectly by the insurer. The taxable basis for FBT can be different from SAT.

 

What are the SAT and FBT filing and payment frequencies in Monaco?

SAT and FBT are filed quarterly on one return. The payment must be made alongside the filing. The settlement deadline is the tenth day of the third month after the reporting period ends.

In addition to the quarterly return obligation, insurance businesses must file an annual return by 31 May of the year after the reporting year.

 

What are the penalties and interest for SAT and FBT in Monaco?

Penalties are imposed for payment delays, as well as inaccuracy, omission, inadequacy, or any other violations that may cause damage to the Monegasque treasury.

The late payment interest rate is 6%, and is charged on the entire month, regardless of when in the month the late payment becomes due. For every other error, the default penalty is EUR 150 or EUR 1,500. The latter applies if the violated legal provision is punishable.

 

What are the challenges for Insurance Premium Tax in Monaco?

The fiscal representation regulations are the most difficult aspect of Monegasque insurance premium taxation. A foreign insurance business must have a representative authorised by the Minister of State to declare taxes in Monaco.

This representative should be a private individual and is fully liable for the payment of any Monegasque duties and fines. In addition, a certain amount of guarantee is payable if the representative is not based in Monaco.

 

Want to learn more about Insurance Premium Tax?

 

Want help with IPT in Monaco?

Speak to our IPT experts

When considering motor insurance, it’s worth remembering that everything is high – from tax rates to the amount of administration required.

This blog includes general information about the taxation of motor insurance policies in Europe, covering the types of applicable taxes, how they are calculated, vehicle exemptions and more. We also have blogs for some of the more complex taxation requirements in the region, written by our regulatory experts.

 

Update: 2 November 2023 by Edit Buliczka

Guarantee Fund Contributions Are Not Payable by Foreign Insurers

The Amendment to the Sixth Motor Insurance Directive, also known as the “MID,” was published in the Official Journal of the European Union on 2 December 2021. MID relates to insurance against civil liability in relation to the use of motor vehicles and the enforcement of the obligation to insure against such liability.

The measures of the Directive 2021/2118 (the “Amendment”), which was signed on 24 November 2021, must be transposed into national law by 23 December 2023, at the latest.

 

Effects of the amendment

Among other important measures, this Amendment is relevant to insurance premium taxation. Two new articles were added to the MID regarding the contributions that may be payable by the insurance companies to the national guarantee funds.

According to Article 10a and Article 25a, every EU Member State is required to ensure that there are sufficient resources available to compensate injured parties in a motor vehicle accident where the relevant insurer is subject to bankruptcy or winding-up proceedings. The insurers may be required to contribute financially to these funds, but only insurance companies authorised by the Member State that imposed the payments may be subject to these levies.

In practice, the measures mean that contributions to the national guarantee funds related to compulsory third-party motor liability insurance policies cannot be collected from foreign insurers that write businesses on a freedom of services (FoS) basis. Since there is a requirement for the implementation of these measurements coming into national law by 23 December 2023, legally no guarantee fund contributions are payable by foreign insurers as of 24 December 2023.

Some governments, including Denmark and Ireland, have already started to draft the necessary regulations and incorporate them into their national laws. Others will likely follow shortly as there are under two months available for the implementation of these rules, at the time of the publication of this update. Perhaps several annual budgets will include the necessary legislative changes to comply with the measurements of the Amendment.

If you would like to receive further information about the guarantee fund contributions, please contact our IPT experts.

 

Insurance coverage in Europe on motor-related risks

According to Annex 1 of the Directive 2009/138/EC of the European Parliament and of the Council of the EU, often known as the Solvency II Directive, motor vehicle insurance policies are classified as Class 3 Land vehicles (other than railway rolling stocks).

This business category covers any damage or loss to:

  1. Land motor vehicles
  2.  Land vehicles other than motor vehicles

Class 10 Motor Vehicle Liability is another business class that covers motor-related risks. This business class covers all risks associated with liabilities deriving from the operation of motor vehicles on land.

A third-party motor vehicle insurance coverage guarantees that if an accident happens and/or damage occurs to another person’s vehicle, the expenses of the accident or damage are covered by the insurer of the person who caused the accident or damage.

We must not forget Directive 2009/103/EC on civil liability insurance for motor vehicles which governs mandatory motor insurance policies throughout Europe. One of the directive’s main principles is that all motor vehicles in the EU must have third-party liability insurance.

We should also mention that the European Parliament and the Council adopted the Directive (EU) 2021/2118 on 24 November 2021, aiming to modernise and amend the aforementioned directive with a deadline for the transposition of 31 December 2023.

In this blog, we outline the main characteristics of the taxation of motor-related insurance policies.

 

Which taxes are payable in relation to motor insurance policies?

Premiums derived from motor-related policies are often subject to several types of insurance premium taxes. Class 3 risks are primarily subject to insurance premium tax (IPT), whereas mandatory third-party liability (MTPL) policies are subject to a wide range of taxes.

This may include IPT and/or payments to guarantee funds, as well as additional levies, charges, or contributions such as:

There is also the traffic safety fee, Automobile Rente (CAR) payment, automobile insurance bureau levy and rescue tax. This list goes on.

The disclosure and payment rules are also diverse. These fees can be paid yearly, monthly, quarterly or in instalments – with or without prepayments or final adjustments.

 

How taxes on vehicle insurance policies are calculated

If IPT is charged on the motor hull or the MTPL policies, it is typically based on the premium amounts received, with the tax being a percentage of the premium. This is not the case in Austria, for example, where the computation of MTPL taxes is complicated.

The tax is calculated based on the engine’s horsepower and CO2 emissions. It also varies depending on the registration date of the vehicle, the frequency of payment and whether the 2017/1151 EU law applies to the vehicle. On top of that, no payment is due if the size of the engine does not reach 24kW or 65 kW. Contrary to the Austrian example, the IPT rate in Hungary is 23% – based on the premium amount.

Contributions to the Guarantee Fund are typically calculated as a percentage of the premium, as in France, Greece or Sweden. However, this fee can also be fixed as it is in Denmark, for example.

 

What vehicles are exempt from tax?

Most countries exempt premium amounts from policies covering motor hull or MTPL risks based on the following:

If the vehicle is operated by the authorities – such as police vehicles, fire trucks, or ambulances – or the armed services, it is typically exempt. Cars driven by disabled individuals and buses used for public transportation are likewise excluded in most cases. Insurance policies covering electric or hybrid vehicles may be excluded as well.

 

How Sovos can help with Insurance Premium Tax on vehicle tax

Sovos can provide advice on motor-related insurance premium taxation. Our compliance team may be able to help you in settling IPT in various countries across Europe, contact us today.

Update: 17 April 2025 by Edit Buliczka

New IPT Prepayment Rules in Hungary

Starting in 2025, new prepayment rules will apply to the Extra Profit Tax on Insurance Premium Tax (EPTIPT). The current structure of two prepayments—due in May and November—will be replaced by a single prepayment, which must be made by 10 December 2025.

In addition to the revised payment schedule, the calculation methodology has also changed. The prepayment amount will now be based on the actual premium collected between January and November 2025, rather than the previous year’s figures.

Insurers may reduce the prepayment amount by 30% of the nominal increase in the value of their government securities portfolio during the same period, as stipulated by the new rules.

Any overpaid prepayment remains reclaimable after the final EPTIPT settlement, which is due following the second instalment—after 31 July 2026.

While this change simplifies the reporting process by reducing the number of prepayment declarations, it also imposes a tighter timeframe. Insurers will have only 10 calendar days to aggregate 11 months’ worth of premium data and assess whether a reduction can be applied. This will likely require additional administrative effort and careful financial planning from the insurers.

 

Update: 20 May 2024 by Edit Buliczka

Hungary Amends IPT Prepayment Rules

In January 2024, the Hungarian government modified the prepayment system for the extra profit tax on insurance premium tax (EPTIPT). These amended rules are first applicable at the end of May 2024, when the 2024 EPTIPT prepayment becomes due.

According to the new rules, the EPTIPT prepayment must be paid in two installments: one in May and another in November.
Both prepayments are based on installments paid for the 2023 final settlement. As a result, the prepayment, due by 31 May 2024, corresponds to the first installment of the 2023 EPTIPT settlement (paid in January 2024). The second installment of the prepayment, due by 15 November 2024, should be equal to the second installment of the final 2023 settlement (payable in July 2024).

Looking for guidance on meeting your IPT obligations? Sovos can help.

 

Update: 20 September 2022 by Edit Buliczka

It’s time to return to Insurance Premium Tax (IPT) prepayments – a continuation of our blog series on this important IPT topic. You can find the first entry in our blog series here.

IPT is declared and settled differently throughout Europe. Monthly, quarterly, or biannual declarations – the frequency varies across Member States – and some jurisdictions request prepayments to ensure the liabilities due from insurance companies are collected in good stead.

Hungary is one country where legislation states prepayments are required. However, the prepayment obligation is a new requirement, introduced alongside the so called ‘extra profit tax’ or supplemental IPT, which is payable on an annual basis. No prepayment is required in relation to the ‘normal’ insurance premium tax paid monthly.

What is a prepayment?

Prepayments are defined as a tax payment credit made to a tax authority before the payment is actually incurred.

This prepayment tax will be deducted to cover the tax liabilities until the total credit is used, then current liabilities must be paid by the basis applied in each “jurisdiction“.

You can learn more about IPT prepayments in our blog.

IPT prepayments in Hungary

Before the introduction of extra profit tax, or supplemental IPT, prepayment for IPT in Hungary wasn’t a requirement. The ‘normal’ IPT is paid monthly with no prepayment obligation and there is no need to submit an annual return.

In Hungary the prepayment concept is used for taxes where there is an annual declaration obligation, such as in the case of corporation tax.

Regarding IPT, the prepayment obligation was introduced with the extra profit tax regime. Extra profit tax or supplemental IPT is an annual tax. This might be the reason for the introduction of the prepayment obligation for this tax type.

Supplemental IPT prepayment is due on 30 November 2022 regarding 2022 (bi)annual supplemental IPT, while for 2023 the prepayment is due by 31 May 2023.

Based on the original concept, the basis of the prepayment for 2022 was the premium collected during the period between July 2021 and June 2022, applying the rates applicable for 2022. However, this was modified shortly after the issuance of the Government Decree of 197/2022 on extra profit taxes.

This adjustment most likely occurred as the original concept would have generated a substantial overpayment since the base period to calculate 2022 prepayment is one year and the supplemental tax is due only for the second half of 2022. According to the updated rules the basis of the 2022 prepayment remained the same but the applicable rates were changed from 2022 rates to the rates normally applicable for 2023. The 2023 rates are half of the 2022 rates, decreasing the prepayment amount by reducing the rate instead of changing the base period from one year to half year.

Regarding 2023, the calculation of the prepayment is equal to the supplemental tax paid for 2022 in January 2023.

The tax office confirmed that any overpayment regarding the extra profit tax/supplemental IPT can be offset against the ’normal’ IPT and vice versa. This is because the extra profit tax has the same tax code (number 200) and is payable to the same bank account as the IPT.

For example, if the prepayment for 2022 is higher than the 2022 extra profit tax there will be an overpayment on the 200 tax account at the end of January. This overpayment can be offset against the January 2023 IPT liabilities which are payable by 20 February 2023. Or if the insurance company has an IPT overpayment at the end of November 2022, this overpayment can be used to cover the extra profit tax/supplemental IPT prepayment obligation.

Take Action

Get in touch with our tax experts today for advice on how to navigate this often confusing IPT procedure.

There are some countries across Europe where declaring and settling insurance premium tax (IPT) and parafiscal charges on time is not enough to prevent late payment penalties. You may ask why. Or you may say it’s unfair. The answer is simple.

Some European countries collect insurance premium tax and parafiscal charges or part of them in advance before they become due for payment. We call these prepayments, advance payments or provisional payments. And missing the deadline for the prepayment can be penalised by the tax offices.

This blog will give you an overview of how prepayment regimes work. At the end of this blog, we’ll list the countries where prepayment rules are in place without detailed requirements. In later blog posts, we will discuss the detailed prepayment rules in these countries in depth.

How do IPT prepayments work?

Prepayment or advance payment in the taxation world is a payment that is paid before the tax is due. Therefore, when a prepayment is paid, it’s unknown how much the actual tax will be.

There are various prepayment tax calculation methods. In IPT, the most common calculation is when the prepayment amount is based on the tax amount paid for the previous reporting period. Either the same tax amount or maybe a certain percentage of this tax is required to be paid in advance. However, there are other methods used.

For example, in Poland, there is a quarterly prepayment obligation. The prepayment amount is based on the premium amounts collected in the current quarter. Another example is in Austria, where there is a unique prepayment approach. According to the regulation, you can opt not to pay the prepayment if you pay the IPT liabilities for the November period one month earlier than the standard deadline, so not by 15 January but on or before 15 December instead.

There are similarities in the legislation on how the amount of the prepayment is considered in the final tax due. In most cases, insurers can offset the prepaid tax amount against the future period`s tax obligation. But there are differences in the “how”.

For example, in Belgium, the prepayment made in December can be offset against the December liability. Also, in January and February (the Belgian Tax Offices recently added these two months), periods’ liabilities and the remaining should be reclaimed. In Italy, the prepayment made in November can be fully offset against the next year’s IPT liabilities and against the following tax years’ liabilities until it is used up entirely. Alternatively, insurers can also reclaim it from the Italian tax authority.

If we take a closer look at the calculation of the prepayment, we can conclude that it’s usually based on the tax amount of the same tax type. However, in Italy, the basis of the IPT prepayment isn’t only the paid IPT but also what has been paid for the 1% Consap parafiscal charge.

When do IPT prepayments need to be made?

The due dates to pay prepayments vary across Europe. Some due dates fall at the end of the year, such as Austrian IPT and the Italian IPT. However, for the Italian Hunting Accident Victims’ Fund (HAVF) and Road Accident Victims’ Fund (RAVF) and the Spanish Fire Brigade Tax (FBT), the advance payment is due in January. The advance payment for the Hungarian supplemental IPT is due in November and May. On the other hand, the prepayment is due every quarter regarding the Polish Ombudsman fee.

Where do IPT prepayment regimes exist in insurance taxation?

Without pursuing completeness, here is a list of the prepayment regimes across the EU:

Take Action

Contact our team of experts today for help with IPT compliance or download our e-book Indirect Tax Rules for Insurance Across the World.

Update 7 October 2024 by Edit Buliczka

Hungarian Tax Office Updates IPT Declaration Form for 2023

The procedure necessary to correct an underdeclared premium figure in Hungary can be complicated. The complexity of a correction for return form 2320 has become even more challenging.

Following a Sovos query, the Hungarian Tax Office (HUTA) updated the 2320 form and issued new guidance for this declaration on 11 September 2024.

This update affects the correction of the final settlement of the extra profit IPT (“EPTIPT”) for 2023. The issue was incorrectly created references on 2320-02, the page dedicated to correcting declared IPT and EPTIPT figures.

The form referred to the whole yearly EPTIPT sum rather than half of the annual sum for the 1st or 2nd instalments (due by 31 January and 31 July, respectively). This resulted in a difference for the whole year rather than a difference regarding the appropriate instalment (half of the annual amount).

Below is an example, using fictitious numbers, to help understand the update.

Thousand HUF
Original amount of the annual EPTIPT for 2023 1,000.00
Half of the original amount of the annual EPTIPT for 2023 (to declare as 1st and 2nd instalment by 31 January and 31 July 2024) 500.00
Additional EPTIPT liability for 2023 (annual figure) 600.00
Half of the additional liability for 2023 (to declare as an addition to the 1st and 2nd instalment by 31 January and 31 July 2024) 300.00
Form 2320, Page 02, Row (C) 8 Original amount Correct amount Difference
Sheet 2320-02 before the update (INCORRECT) 1,000 1,600 600
Sheet 2320-02 after the update (CORRECT) 500 800 300

As the table shows, before 11 September 2024, the underdeclared amount was shown as the total annual difference rather than the underdeclared 1st or 2nd instalment (i.e. half of the total annual liability).

This amount was then recorded as the underdeclared liability on the HUTA tax account, which was requested to be paid alongside the submission of the corrective tax return. The self-revision fee should have been calculated on this amount (i.e. double the actual underpayment).

Not paying this double amount could have resulted in an underpayment on an insurer’s HUTA tax account. This underpayment then will have been subject to the late interest fee payable in November 2025.

In summary, the incorrect formula on page 2320-02 could have resulted in:

  1. Underpayment of EPTIPT
  2. Double the self-revision fee
  3. Late interest fee payable by November 2025

Based on guidance received by Sovos, HUTA will soon rectify the incorrectly recorded correction of 2023 EPTIPT. This will have a consequence of avoiding the imposition of the late interest fee in 2025 for 2024.

If you are in this situation and need help, please do not hesitate to contact our expert team.

 

Update: 20 May 2024 by Edit Buliczka

Hungary Amends Extra Profit Tax Declaration and Prepayment Rules

In May 2023, the Hungarian government extended the extra profit tax on insurance premium amounts (EPTIPT) for another year.

It updated the regulations again in January 2024, adding the fourth amendment to the two-and-a-half-year history of this tax (this tax was supposed to be repealed from 2025). This time, the final settlement and prepayment declaration and payment rules were modified.

According to the new rules, both the final settlement and prepayment must be paid in two installments. The same exact amount should be settled four times over the year – as follows:

Both the final settlement and the prepayment installments should be equally split between these deadlines.

If an insurance company needs to correct the declared premium amount for 2023, for example, in August 2024, it must submit four corrective tax returns in a row:

If such an error is discovered after 15 November 2024, the number of corrective returns will rise to five. Taxpayers would also need to submit the corrective 2024 EPTIPT second installment prepayment return.

Do these changes add administrative burden to your organisation? Speak to Sovos about how we can help.

 

Update: 26 January 2023 by Edit Buliczka

Hungary: Return template for 2023 published

The Hungarian Tax Office (HUTA) released the 2023 insurance premium tax (IPT) return template last month.

According to the government decree of 465/2017, return templates must be made available at least 30 days before the due date. The first IPT return of the year is due by 20 February 2023, pertaining to the monthly IPT liabilities for January 2023.

The new IPT return template replicates the template from 2022, though the code, rates and scales for 2023 extra profit tax (EPTIPT) are different.

Coding of the tax returns in Hungary are usually formatted so that the first two digits indicate the tax year – in this case, 23 for 2023 – and the remaining digits, which are typically numbers, specify the type of tax. IPT and EPTIPT fall under the same tax code of 20. Therefore, the IPT/EPTIPT return code for 2023 is 2320.

Based on advice obtained from HUTA, it was confirmed to Sovos that the return template will not refer to the declared EPTIPT prepayment. Instead, the difference between the final EPTIPT liability and the declared EPTIPT prepayment will be recorded as an additional debt or overpayment on the HUTA tax account. As a result, insurers must manually calculate the payable EPTIPT and make their payments accordingly.

Download our free IPT compliance eBook for additional information or read our guide to Insurance Premium Tax.

 

Update: 30 December 2022 by Edit Buliczka

Hungary: Increased insurance Extra Profit Tax 2023 rates

It’s been less than a month since the Hungarian Tax Office (HUTA) published instructions for insurance premium tax (IPT) for 2023 and the rules have already been amended.

The amendment is in line with the recently issued government decree (No. 582/2022) published on 24 December 2022. This alters the tax rates for 2023.

The update affects the final scale (premium collected in 2023 exceeding 36 billion Hungarian Forints) in relation to non-life and life insurance premiums.

The rates for premium amounts collected from non-life policies climbed from 7% to 12%. Rates for premium amounts collected from life policies grew from 3% to 5%.

Need more information about Hungary’s Extra Profit Tax? Speak with our Insurance Premium Tax experts.

 

Update: 15 December 2022 by Edit Buliczka

Hungarian Tax Office publishes extra profit tax and prepayment rules for 2023

On 29 November 2022 the Hungarian Tax Office (HUTA) published instructions for the insurance premium tax (IPT) rules applicable for 2023 liabilities. This guidance includes the rules for extra profit tax and extra profit tax prepayment payable for 2023.

The information provided for 2022, including the section about the overpayment of the extra profit tax prepayment, is essentially repeated in this guidance. It states that reclaims are possible for any overpaid prepayment. The question is how? Even if the HUTA hasn’t released the referenced 2320 declaration form yet, if the 2320-04 additional profit tax settlement page of the return doesn’t change, the oddity we highlighted in our earlier update on 14 November  2022 still exists. The anomaly is: Is the entire declared extra profit tax payable again? Can we deduct the prepayment that was previously made? If yes, how?

Another notable piece of information in the new guidance is the date of the extra profit declaration for 2023. It states that the due date is 30 January 2024. This date is 31 January 2024 according to the government decree.

We are hoping these anomalies will be cleared before the extra profit tax for 2022 is due, that is by 31 January 2023. We are going to update this blog once new information is available.

Read our IPT compliance guide for further information.

 

Update: 15 November 2022 by Edit Buliczka

Hungary: anomalies around insurance premium extra profit tax

On 2 November 2022 the Hungarian Tax Office (HUTA) published the declaration form for settling the insurance premium extra profit tax or supplemental insurance premium tax (EPTIPT) prepayment and the extra profit tax.

In this update we will be discussing anomalies around the declaration form’s publish date, its content, and its guidance.

Facts about insurance premium extra profit tax in Hungary:

The publish date of the extra profit tax declaration form

1. In its guidance issued to Sovos, HUTA confirmed that if an insurance company with Hungarian tax registration terminates its taxable activity in Hungary, deregistering between July 2022 and the issuance of the declaration form, the company is liable to declare its extra profit tax liabilities at the date of the deregistration. HUTA adds that since the Decree determined a final settlement deadline of 30 November for extra profit tax prepayment and 31 January 2023 for extra profit tax, the deregistering insurer can and should fulfil its obligation before these final deadlines. The compliant approach for the date of deregistration in Hungary is 15 days following the termination of the activity.

Anomaly: How it is possible to settle extra profit tax liabilities and submit a declaration (online submission is compulsory in Hungary), for example on 15 September, if the declaration form has not been published by that date?

 

2. According to a government decree (No. 465/2017 on the detailed rules of tax administration) the declaration forms should be published at least 30 days before the tax due dates unless there were adjustments in the regulation during this period.

Anomaly: Although both 31 October and 1 November were public holidays in Hungary in 2022, the phrase “at least” suggests the form was published before the public holidays, leaving more than 30 days for taxpayers to prepare rather than less.

Extra profit tax declaration form and guidance

1. Separate sheets were created in the declaration form for ‘normal’ or monthly insurance premium tax (IPT), the insurance premium extra profit tax prepayment and the insurance premium extra profit tax. The sheet for the settlement of extra profit tax does not include a line to deduct the amount of the prepayment.

In the guidance issued by HUTA to Sovos, it states that as the monthly insurance premium tax, the extra profit tax prepayment and the extra profit tax have the same tax code (No. 200), all payments can be automatically offset against each other.

Anomalies:

2. Based on the guidance and as per the declaration form, corrective/substitute return should be submitted in relation to ‘normal’ IPT, extra profit tax prepayment and extra profit tax if the amount of these liabilities appears to be incorrect following the submission of the return.

Anomalies

The above anomalies are just examples around the extra profit tax prepayment and extra profit tax declaration. Sovos submitted queries to HUTA to clarify these anomalies. We predict some of these anomalies will be clarified soon with the issue of an adjusted declaration form and an amended guidance.

Still have questions about Hungary’s supplemental insurance premium tax? Get in touch with our Insurance Premium Tax experts.

 

Update: 11 July 2022 by Edit Buliczka

As of 1 July 2022, Hungary introduced an Extra Profit Tax scheme, which levies supplemental Insurance Premium Tax (IPT) on insurance premiums. The introduction of the Extra Profit Tax scheme is a temporary measure and aims to cover the increased governmental costs caused by the conflict in Ukraine. The Extra Profit Tax scheme is applicable not only for the insurance sector but also for other sectors, including airlines, medical, energy, telecommunications and banking.

The following blog gives an overview of this tax, highlighting some interesting features and anomalies around this tax.

What is Hungary’s Supplemental Insurance Premium Tax?

On 4 June 2022, a Government Decree was published in the Hungarian Official Gazette, numbered 197/2022, with the title “About Extra Profit Taxes”. One may wonder why a government decree regulates a new tax method. To answer this question, we need to research and read the Hungarian Constitution and another law about special measurements in case of catastrophes. Adding two new sections to the mentioned law on 25 May 2022 made it possible for the government to introduce the Extra Profit Taxes in a government decree instead of adjusting the relevant laws. The Extra Profit Tax scheme includes the Supplemental IPT. Although the Government Decree refers to particular tax laws, such as the 102/2012 IPT Law, the Extra Profit Tax regulations are not and will not be built into these tax laws.

Overview of Hungary’s Supplemental Insurance Premium Tax

Hungary’s Supplemental Insurance Premium Tax is a temporary tax effective as of 1 July 2022 for 18 months and will end on 31 December 2023. This tax is due on non-life and life insurance policies written by both Freedom of Establishment and Freedom of Services insurers. A similar sliding scale system on the income collected is applicable for this new supplemental IPT as it is for the existing IPT. The scales for 2022 are as follows:

  1. Under 1 billion Hungarian Forint (HUF)
  2. Over 1 billion and below 18 billion HUF
  3. Over 18 billion HUF

While for 2023, the scales are the following:

  1. Under 2 billion HUF
  2. Over 2 billion and below 36 billion HUF
  3. Over 36 billion HUF

The rates vary depending on when the taxpayer collected the premium and the type of insurance policies. In 2022 the rates are higher for non-life and life insurance policies than in 2023, also noting that the life rates are half of those applied to non-life policies. For further details about the rates, please read our tax alert, Hungary: Supplemental IPT Introduced Due to Ukraine Conflict.

The declaration and the payment are due by 31 January 2023 and 31 January 2024, respectively. There is also a prepayment obligation for both years with due dates of 30 November 2022 and 31 May 2023. For further details about the prepayment, please also refer to the above mentioned tax alert.

Interesting features about the Supplemental IPT

The introduction of this tax is one of the features which is unique in taxation. In Hungary, in normal circumstances, taxes are introduced, or the existing taxes are modified via laws. Generally, tax laws should be published at least 30 days before they come into effect. In the case of the Extra Profit Tax scheme, the legislative body fulfilled none of the above.

Another interesting feature to mention is that although it is called supplemental insurance premium tax, it is also due on life insurance policies. In Hungary, there is no existing insurance premium tax on life policies as these policies are exempt.

No prepayment is due for the existing IPT, but prepayment is due to be paid for the supplemental IPT.

Supplemental IPT is a type of Extra Profit Tax, but it seems that there is no separate tax code given to it. The Supplemental IPT should be declared on the IPT declaration form and paid to the same Hungarian Tax Office account as the existing IPT.

Anomalies and open questions around Supplemental IPT

The base period to calculate 2022 prepayment is one year, although Hungary’s supplemental insurance premium tax is due only for the second half of 2022. On the other hand, the prepayment for the whole 2023 year is equal to the amount of the half-yearly 2022 supplemental tax. As such, insurance companies will likely overpay the tax with the 2022 prepayment. This overpaid tax will then need to be reclaimed or can be offset against the existing IPT or used for the 2023 prepayment or 2023 supplemental IPT. Is it for purpose or just a mistake and it will be amended?

In the guidance issued by the Hungarian Tax Office on 1 July 2022 on supplemental insurance tax rules for 2022, the tax authority mentioned that taxpayers should declare the supplemental tax on the standard IPT tax declaration form, 2220. However, the tax authority did not update the form by 1 July 2022. As the due date of the prepayment and the supplemental tax differ from that of the existing IPT, there is still an open question of how the form will look to make the distinction between the existing IPT, the prepayment and the supplemental tax. Hopefully, a new return template will be published soon to answer these questions.

As explained above, there is still ambiguity and questions around this new tax. Sovos is dedicated to keeping our clients up to date and informing you as soon as the clarified information is available. Please contact our dedicated IPT compliance team if you have any questions.

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Knowing how to calculate IPT and the corresponding parafiscal surcharges (hereinafter collectively referred to as IPT) is an art. Rules differ by national jurisdiction so ensuring compliance with IPT obligations is not just a regulatory requirement for insurers – it’s essential to avoid financial penalties and reputational risk.

That’s why it’s critical to have a clear understanding of which tax rules apply to the insurance products underwritten, and to stay informed about the specific requirements in each relevant jurisdiction.

This blog will provide an overview of IPT calculations, explaining how to calculate IPT, the different methods of calculation, IPT rates and exemptions, and more. If you’ve found yourself asking, “How is IPT calculated?” then read on, because this page is for you.

How to Calculate IPT: Two Main Methods

There are two basic methods for calculating the tax on insurance premiums in Europe:

  1. Percentage of the Premium/sum insured
  2. Fixed amounts per policy/insured

These calculation models are just the basics; IPT regulations are built upon these models, adding several specific rules, which can make an IPT calculation fairly complex.

Percentage of Model

For the first calculation method, the Percentage model, one or multiple tax rates apply depending on the risks covered.

For example, businesses in Bulgaria can easily determine the tax amount by multiplying the taxable basis by the country’s 2% tax rate. This rate applies to all classes of businesses. However, in Italy or France, the applicable tax rate depends on the risks covered.

Several IPT calculations are based on this basic rate model but there are some models where the tax rate applies on the sum insured value and not on the premium amount.

Fixed Amount Model

In the second calculation method, the Fixed Amount Model, local regulations determine the tax amount that needs to be multiplied – usually per policy, but sometimes per insured person.

Irish Stamp Duty and Danish Guarantee Fund contribution are examples of this calculation method in practice.

 

Key Variables That Impact IPT Amount Calculation

While many factors can ultimately impact the IPT amount calculation, there are certainly some primary factors that many calculations will need to get right.

 

Step-by-Step Example: How to Calculate IPT

While each IPT calculation will vary based on the factors at play, we can provide a sample calculation to illustrate how the process can work.

Identify Risk Class

The first step is to identify the risk category the policy falls under, as this will dictate the location of risk.

Determine the Location of Risk

Determining the location of the risk(s) will determine the country of which the IPT calculation rules apply. Most European countries include a section in IPT regulations to determine the location of risk, citing the Solvency II EU Directive location of risks (LoR) rules.

Determine the Reporting Currency and the Exchange Rate

The reporting currency is the currency in which the tax should be settled to the local tax office. If the premium amount in the policy is determined in a currency other than the reporting currency, then it is important to use the correct exchange rate. Exchange rate rules are not harmonised in the EU. It can be the national bank average monthly/quarterly rate, or rate on the last day of the reporting period.

Calculate the Taxable Basis

The taxable basis is vital for determining the compliant IPT and parafiscal amounts. Look for the local legislation for the definition of the taxable basis. Taxable basis can be the net premium, the sum insured, the value as per the land registry, or net premium plus fees, commissions or even taxes.

Choose Applicable Rate or Fixed Amount

Knowing the correct tax rate/fixed amount is vital. Search for the local IPT legislation, review the risk covered and determine the correct tax rate.

Apply Any Parafiscal Charges

Depending on the risks covered, some countries also levy parafiscal charges on insurance premiums, impacting the total IPT amount to be paid. France is an example of a country that levies various surcharges on the premium amounts depending on the risk(s) covered.

Search for the Exemptions

It is also vital to determine which insurance premiums fall into an exempt class. Usually, risks covering international or exports class of businesses are exempt, such as export credit, or international goods in transit. Some of the EU countries exempt sickness policies too.

Verify Rounding Rules

Lastly, it is essential to follow rounding rules when calculating the total IPT amount to be settled towards the local tax offices, because the settlement of the IPT amount can be rounded. In France, for example, you are required to round to the nearest whole EUR. In Hungary, IPT is declared in thousands HUF.

 

What are some common mistakes in IPT calculations?

With IPT often being complicated to calculate, especially if you don’t know the nuances of the country where the location of risk sits, mistakes can be common.

There are simple mistakes like determining the wrong location of risk or using the incorrect or out-of-date IPT rates (e.g. incorrectly interpreted transitional rules), and misunderstanding exemptions.

More errors come from miscalculating the value of the premium or the sum insured or incorrectly applying surcharges.

 

Rules for IPT amount calculation

There are rules taxpayers must abide by to comply with IPT regulations. Here is a selection of IPT rules for amount calculation.

Here are some examples of these specific rules:

 

Conclusion

As you can tell, IPT calculations can be complex—but they don’t need to be. If you are aware of the common pitfalls and the key considerations in these calculations, you can work out the amount payable with accuracy and confidence.

Knowing the rules and requirements of the country you are operating in is key, from the tax rate to how they require insurers to calculate Insurance Premium Tax. Non-compliance can be costly, both financially and reputationally, so be sure to put your best foot forward by knowing how to calculate IPT correctly.

 

FAQ

What countries use a sliding scale for IPT?

Hungary is the only country that utilises a ‘pure’ sliding scale rate model to calculate its Insurance Premium Tax. The sliding scale model is a method of calculating IPT where the tax rate changes once the insurance premium exceeds a threshold. Malta, on the other hand, applies a mixture of fixed amount and sliding scale model.

Can IPT be refunded if a policy is cancelled?

Yes, there is generally a chance that Insurance Premium Tax (IPT) can be refunded on a cancelled policy. Refunds are done pro rata on policies that have been active for longer than the mandatory 14-day cooling-off period. There are exemptions from this general rule, with the best example being Italy.

Does IPT apply to reinsurance?

While countries have their own nuances regarding IPT, the general rule of thumb in countries like the UK is that Insurance Premium Tax does not apply to reinsurance.

This is because countries like the UK want to avoid double taxation, as the original direct insurance policy is already subject to IPT.

Is IPT calculation harmonised in the EU?

No, IPT is not harmonised in the EU. Although the Solvency II EU directive provides some basic rules which are mandatory for EU countries to follow, the specifics of the IPT calculation, such as the rates and taxable basis are not harmonised.

What is the highest and lowest IPT rate in the EU?

Currently, the highest IPT rate in the EU is 30%, applying to certain policies in France. The highest generic IPT rate of 25.5% applies in Finland. The lowest IPT rate, not mentioning the exemptions, is the 1.4% IPT rate applied for certain specific policies in Belgium. The lowest generic IPT rate is 2% in Bulgaria.

How do you calculate IPT?

Put simply, Insurance Premium Tax (IPT) is calculated as a percentage of the insurance premium. The percentage, also known as the IPT rate, depends on the type of insurance policy and the rates of the country to which the policy applies.

To calculate the IPT amount, you multiply the insurance premium by the appropriate tax rate. The insurer then adds the cost to the figure paid by the policyholder.

This calculation is the simplest, but it’s worth mentioning that there are various calculation methods e.g. fixed amount method, sliding scale methods.

What factors influence IPT calculation?

There are various factors that need to be considered to compliantly calculate IPT. These factors include, but are not limited to, location of risk, the risk covered, the exchange rate, the definition of the taxable premium, the IPT and parafiscal tax rates and the exemptions.

Last updated: 19 July 2023

Insurance Premium Tax in Croatia

Under the Freedom of Services (FoS), Croatia currently levies an Insurance Premium Tax (IPT), Compulsory Health Insurance Contributions (CHIC) and Fire Brigade Charge (FBC) on the premium amounts of insurance policies written by EU and EEA insurance companies.

In Croatia, IPT only applies to selected classes of business such as motor coverage, which includes the mandatory Motor Third Party Liability insurance policies. Only the latter policies are subject to CHIC. FBC is applicable only to fire premium amounts.

Read on to understand the different IPT requirements and classes of business in Croatia.

Insurance Premium Tax (IPT)

There are currently two different IPT tax rates in force for motor insurance policies in Croatia:

Motor vehicle IPT is an insured-borne tax that is required to be reported monthly and payable within 15 days following the end of the month. There is an annual Motor IPT Report obligation too, which must be submitted on 31 January following the end of the reporting year.

Compulsory Health Insurance Contributions (CHIC)

This contribution is payable to the Croatian Institute of Health Insurance but must be disclosed quarterly to the Croatian Tax Office. In addition, the annual return must be submitted to the Tax Office by 30 April.

Until 31 March 2023 the rate of the contribution rate was 4%. The rate was raised to 5% as of 1 April 2023.

Fire Brigade Charge (FBC)

The Act on Firefighting governs the fire brigade regime in Croatia. The FBC rate on fire insurance premiums is 5%.

The law does not include a definition for the fire premium. Sovos gained clarification on the definition of the fire premium from the Croatian Financial Services Supervisory Agency (HANFA), the body which supervises FBC. HANFA indicated there is no specific definition of the fire premium, but the insurance company should determine this amount on a case-by-case basis.

The declaration on the fire premium is due annually, by the end of February following the payment year. The return should be submitted to the Croatian Firefighter Association.

There is no set date in the law for the payments, but payments are said to be due at least quarterly.

5% FBC payments should be split and sent to:

If you would like to settle this tax compliantly:

Firstly: You need to know the postcode of the property. But what is the postcode of an immovable property?

Secondly: You need to match a county with a postcode. This would not be too challenging as the first two digits of the five-digit Croatian postcode reveal the county’s name if you search Croatian postcodes online.

Thirdly: You need to know your local firefighting organisation’s name and bank account number or, if these organisations have established an association, the association’s name and bank account number. That is difficult but not impossible if you know where to look.

Finally: In the annual return you need to list each payment you made in the previous year.

Following the complaint method might be time-consuming if the insurance firm has written multiple fire businesses in Croatia. Because there is no minimum contribution threshold, even EUR 0.01 cent FBC should be paid to the local firefighter’s organisation or association (i.e., 40% of FBC)

Sovos has developed a robust system to settle your Croatian fire brigade charges. We have also established a constructive relationship with the Croatian Firefighters Association and HANFA.

Please contact our representative for information, or if you would like to appoint Sovos as your IPT representative in Croatia.

Treatment of fire charges is tricky in almost all jurisdictions. Fire coverage can vary from as high as 100% to 20%.

No-one would dispute that the most complex fire charge treatment is in Spain. In Portugal, whilst the rules are less complex, they have a unique reporting system for how the policies covering fire must be reported.

How Portuguese Fire Brigade Tax reporting is unique

The Portuguese Fire Brigade Tax (FBT), otherwise known as National Authority for Civil Protection Fire Brigade Charge or ANPC (Autoridade Nacional de Proteção Civil), is due on certain policies covering fire risks. Such policies can be mapped as Class 3-13.

The tax rate is 13%, but usually the fire coverage is set at 30%, so the applied rate is only 3.9%. As per market practice, if the fire proportion is not separately identified in the policy, then 30% fire proportion is assumed. ANPC is settled to the ASF (Autoridade de Supervisão de Seguros e Fundos de Pensões), the body that administrates parafiscal taxes in Portugal, on a monthly basis together with the other parafiscal taxes such as INEM (medical emergencies). There is currently no speciality in the regulation.

The unique feature of the Portuguese fire tax is the five yearly reporting requirement. This five yearly report was last due in 2016 and will be due again in 2021. The report requires insurers to prepare a summary which lists total ANPC or Fire taxes paid in respect of the year when it’s due. So although the report itself is due every five years, the reportable policies are limited only to the policies subject to ANPC in that reporting year.

Another unique feature of this reporting is that although all insurers are subject to settle ANPC liabilities monthly, not all insurers are necessarily obliged to submit this report. ASF informs the insurance companies who are required to submit this report.

How to report Portugal’s Fire Brigade Tax

Reporting is biannual. In 2016 the first semester data (01-01-2016 to 30-06-2016) was due to be reported by 31 August 2016 and the second semester data (01-07-2016 to 31-12-2016) was due by 28 February 2017.

In 2016, when this report was last due, ASF issued an official circular about the reporting requirements. A template has been published to provide help for insurance companies to fulfil their obligations.

In 2016 the report requested a total of the ANPC charges per county and per district. That included more than 300 districts. As yet, we’ve not seen a circular about the requirements for 2021, so we’re in contact with ASF to find out if the report is still due and if yes, the requirements and when the notifications will be sent to the insurance companies.

We hope the complexity of this reporting hasn’t been further increased by the ASF. This unique reporting is time consuming for insurance companies and looking at the global trends in reporting requirements we expect the FBT report will still be due this year.

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