A non-EU buyer in Hungary needs a permit from the county government office for any non-farm property, apartments included. Fee 65,000 forints per property, deadline 45 days.
Hungary charges the buyer a 4% property transfer duty on market value. In Romania the buyer pays no transfer tax; the seller pays 1% or 3% of the price.
Hungary's guest investor permit requires €250,000 in units of a registered real estate fund or a €1 million university donation. Buying a home directly is not a listed route.
Romania vs Hungary property: the short answer
Both countries are EU and Schengen members with their own currency. In Hungary, a buyer who is not a citizen of an EU or EEA state needs a permit from the government office (kormányhivatal) of the county where the property is, for any property that is not farmland. That includes an apartment. The fee is 65,000 forints per property and the deadline is 45 days. Farmland and forest are closed to non-EU individuals. In Romania nobody needs a permit to buy a building, but a non-EU citizen cannot register the land directly in their own name.
On costs, a Hungarian buyer pays a 4% property transfer duty on the market value. In Romania the buyer pays no transfer tax. On a new home, Hungary applies a reduced 5% VAT until the end of 2026, under conditions; Romania applies 21%.
In plain words: in Hungary every purchase by a non-EU buyer goes through a permit and a 4% duty; in Romania there is no permit and no transfer tax, but the land under a house needs a structure.
Our earlier article compared prices in Bucharest, Budapest and Prague. This one compares the rules, costs and status.
The big picture
| Romania | Hungary | |
|---|---|---|
| EU member since | 2007 | 2004 |
| Schengen | Full member since 1 January 2025 | Since 21 December 2007 |
| Currency | Romanian leu | Hungarian forint |
| Permit to buy a home (non-EU buyer) | Not required | Required, including for an apartment |
| Land for non-EU buyers | Not directly in their own name | Building plots with a permit; farmland and forest closed |
Purchase rules for foreigners
Hungary: a permit from the government office
The rule sits in Act LXXVIII of 1993 and Government Decree 251/2014. A "foreign" natural person is defined as someone who is not a citizen of an EU or EEA state or a state treated the same way by treaty. Such a buyer needs a permit to acquire real estate that is not agricultural or forest land, whatever the type: apartment, house or plot. Inheritance is excluded.
How it works:
- Where: the capital or county government office where the property is located.
- Fee: 65,000 forints per property (Act LXXVIII of 1993, §1/B).
- Deadline: 45 days (Decree 251/2014, §3).
- The test: the purchase must not harm the public interest or the interest of the local municipality. A criminal record counts as harm to the public interest. Since a 2025 amendment, the municipality's local identity protection rules also count.
- Reciprocity: the office may refuse if the buyer's home state does not give Hungarians equal treatment. Reciprocity is presumed unless the foreign minister states otherwise.
Farmland and forest: under Act CXXII of 2013, a foreign natural person, meaning someone who is not a citizen of an EU member state, cannot acquire agricultural or forest land at all.
Romania: the building yes, the land through a structure
In Romania nobody needs a permit to buy an apartment or a house. A citizen of a non-EU state, such as an Israeli without an EU passport, registers the building in their own name. The land is different: under Article 44(2) of the Constitution and Article 6 of Law 312/2005, non-EU citizens acquire land only under an international treaty, on a reciprocity basis. For a villa, the usual routes are a superficies right (superficie) or a Romanian company. We explain both in our guide to land ownership in Romania.
The practical difference: in Hungary, an Israeli buying an apartment waits for a permit; in Romania, the same buyer goes straight to the notary.
Purchase costs and taxes
| Romania | Hungary | |
|---|---|---|
| New home from a developer | 21% VAT | 5% VAT on apartments up to 150 m² and houses up to 300 m², until 31 December 2026 (transition to 2030 for projects permitted by end-2026); otherwise 27% |
| Transfer tax | None for the buyer | 4% property transfer duty on market value, paid by the buyer |
| Notary or lawyer | Notary on an official sliding scale (UNNPR), plus VAT | Ask the lawyer or notary for a written fee quote |
| Registration | Land register fee of 0.15% for individuals | Fixed land registry fee per property |
| Foreign buyer permit | None | 65,000 forints per property |
Two Hungarian details. The 4% duty rate applies up to 1 billion forints of value per property, with 2% above and a cap of 200 million forints (Duties Act, §19). A buyer who sells another home within five years before, or one year after, the purchase pays duty only on the difference in value (§21). Smaller reductions exist for new homes and for buyers under 35, but only at low values (15 million forints).
For the Romanian side, see our guide to property buying costs in Romania.
Ownership costs
Romania: an annual local tax on the building, 0.08% to 0.2% of its taxable value, set by the local council, plus a land tax. The base rose from 2026 under Law 239/2025.
In Hungary every purchase by a non-EU buyer goes through a permit and a 4% duty; in Romania there is no permit and no transfer tax, but the land under a house needs a structure.
Hungary: there is no national annual property tax. Each municipality may introduce a building tax (építményadó) by local decree. The law caps it at 1,100 forints per m² of usable area, or 3.6% of the adjusted market value, indexed for inflation since 2003 (Act C of 1990, §§6 and 16). Some municipalities charge it on homes and some do not, so ask the town hall.
Selling tax
- Romania: a tax on the sale price, not on the gain: 3% if you held the property for up to three years, 1% if longer. The notary collects it on signing day. See our guide to tax on selling property in Romania.
- Hungary: 15% personal income tax on the gain from a home sale. The taxable part falls the longer you hold: according to the tax authority NAV, it reaches zero in the fifth year after the year of purchase. You declare it in the annual return for the year after the sale.
Your country of residence may also tax the gain.
Financing for non-residents
Romania: for foreign buyers, financing of up to 70% of the price is possible, with equity of at least 30%.
Hungary: banks lend under the central bank's debt-cap decree (MNB Decree 32/2014). It caps the loan as a share of the property value, generally 80% for a forint loan, with lower caps for loans in euros or other currencies. Each bank sets its own rules for non-resident income. Ask for the currency, the maximum loan and the accepted documents in writing.
Residency
Hungary has a guest investor residence permit under Act XC of 2023. As of October 2026, the law lists two qualifying investments: at least €250,000 in units of a real estate fund registered with the central bank (held for at least five years), or a donation of at least €1 million to a higher education institution run by a public-interest foundation. Buying a home directly is not one of the listed routes. The permit can be valid for up to ten years.
Romania has no investor residence route. You need work, business, family, studies or the digital nomad route. See our guide to the residence permit in Romania.
In both countries, a non-EU visitor counts days under the Schengen rule: up to 90 days in any 180.
Lifestyle: Budapest or Bucharest–Ilfov
In Hungary, the foreign buyer's market centres on Budapest, with Lake Balaton as the familiar holiday region.
Romania's market is centred on Bucharest–Ilfov. According to the National Institute of Statistics, about 17,300 new dwellings were completed there in 2025, about 29% of the national total. The northern suburbs, near the airport and the international schools, are a market of family homes with gardens.
Checklist before you choose
- Your passport. EU or EEA citizen? In Hungary no permit; in Romania you buy land directly.
- The permit timeline. In Hungary, build 45 days, plus the time to prepare the file, into the contract dates.
- The duty and the VAT. In Hungary, 4% duty, and check whether the new project still qualifies for 5% VAT after 2026.
- Local tax. Ask the Hungarian municipality whether it charges building tax on homes.
- The financing. Bank terms for non-residents, in writing.
- The exit. Write down the purchase date. It decides the selling tax in both countries.
- An independent lawyer in the country where you buy, who represents only you.
Frequently asked questions
Do Israelis need a permit to buy an apartment in Hungary?
Yes, unless they hold an EU or EEA passport. Any non-EU buyer needs a permit from the county government office for property that is not farmland, including an apartment. The fee is 65,000 forints per property and the deadline is 45 days.
Can a non-EU citizen buy farmland in Hungary or Romania?
Not in Hungary: Act CXXII of 2013 bars foreign natural persons from acquiring agricultural or forest land. In Romania, non-EU citizens do not register any land directly; a house plot is held through a superficies right or a company.
Is there a transfer tax in Hungary and in Romania?
In Hungary the buyer pays a 4% property transfer duty on market value. In Romania the buyer pays no transfer tax; the seller pays 1% or 3% of the price.
Does buying a home give residency in Hungary?
Not directly. Hungary's guest investor permit requires €250,000 in units of a registered real estate fund or a €1 million donation to a university foundation. Buying a home is not a listed route. Romania has no investor route at all.
What is the selling tax in Hungary?
15% on the gain, with the taxable part falling each year you hold the home and reaching zero in the fifth year after the year of purchase.
The bottom line
Hungary asks more of a non-EU buyer at the start: a permit for every purchase and a 4% duty. It offers a lower VAT rate on qualifying new homes until the end of 2026 and a selling tax that fades out after five years. Romania has no permit and no buyer transfer tax, but the land under a house needs a legal structure.
If you are weighing the two, book a half-hour call with me. We will put the property you are looking at in each country into one table: the rules, the full cost and the exit.
Moti Azulay, Compass Group Romania
Sources: Hungary, Act LXXVIII of 1993, §1/A, §1/B, §91/A (njt.hu, version 1.10.2026) · Hungary, Government Decree 251/2014 (njt.hu) · Hungary, Act CXXII of 2013 on agricultural and forest land, §§5, 9, 10 (njt.hu) · Hungary, Act XCIII of 1990 on duties, §§19, 21, 26 (njt.hu) · Hungary, NAV: 5% VAT on new homes extended · Hungary, VAT Act CXXVII of 2007, §82 (njt.hu) · Hungary, Act C of 1990 on local taxes, §§1, 6, 16 (njt.hu) · Hungary, NAV: taxation of property sales · Hungary, Act XC of 2023, §§16, 22 (njt.hu) · Hungary, government office land registry fees · Romania, Law 312/2005 · Romania, Fiscal Code, Law 227/2015 · ANCPI · National Institute of Statistics, Romania (INS)
This article is for general information only and is not legal, tax or financial advice. The rules are current as of 22 October 2026 and change in both countries; Hungary's 5% VAT on new homes is due to end on 31 December 2026. Before a transaction, consult an independent lawyer and a tax adviser in the country where you buy.
Now you know more.
This article is general information, not legal, tax or financial advice. Consult local professionals before any transaction.
