News, analyses, publications
The United States gave Notice of Termination to Hungary in relation to the U.S-Hungary double tax treaty. On 8 July 2022, The Government of the United States took an unusual measure by sending a formal notification to Hungary with the intention to terminate the effective double tax treaty [...]
The judgement of the European Court of Justice (ECJ) in case C-333/20. Berlin Chemie A. Menarini is a new milestone in the interpretation of the concept of ‘fixed establishment’. From the viewpoint of the recipient of the services, the concept of fixed establishment is determined by Article 11(1) [...]
On 22 December 2021, the European Commission published a proposed Directive targeting aggressive tax planning techniques linked to the use of shell companies. On this basis, starting from 2024, all legal entities tax resident in the European Union (EU), irrespective of their company form, will be classified through [...]
The two-pillar initiative of the OECD and G20 countries was originally drafted about two years ago with the aim to combat harmful tax practices and create a fairer global system for corporate taxation. […]
A new bill (Act CXXXI of 2021), published on 17 December 2021, aims to mitigate the payroll tax burdens raised in connection with the hike of the minimum wage for 2022. […]
In the Hungary-related case of FGSZ Földgázszállító Zrt., the European Court of Justice (ECJ) held that the limitation period for VAT-reclaims on bad debts should be calculated from the date when the receivables had been recorded as irrecoverable, notwithstanding the limitation period of the VAT liability on the [...]
Enterprises struggling with the economic effects of the COVID-19 pandemic might face financial difficulties driving them to carry out share deal transactions. By the wording of the Hungarian VAT Act, such sales qualify as VAT exempt transaction, without the right to deduct input VAT, which implies that general [...]
On 6 October 2021, the European Court of Justice (ECJ) disclosed a Hungary-related judgement in case C-717/19. Boehringer Ingelheim RCV GmbH & Co. KG Hungarian Branch. This new judgment seems to be a new milestone in proceeding in Hungarian VAT legislation. In the preceding years, the ECJ gave [...]
In our current newsletter, we describe the measures announced in June in order to further mitigate the consequences of the COVID epidemic. Tax administration rules In 2021 only once, a surcharge free payment facility can be requested for a tax debt of up to HUF 5 million. The [...]
The recently announced summer legislative package covers several taxes, which has been implemented partly in a clarifying and partly in a supplementary/amending manner. Some changes entered into force after promulgation, others will take effect on January 1, 2022. In our current newsletter, we describe those considered to be [...]
As we presented in our newsletter on 2021 changes in tax regulations, the VAT e-commerce package will enter into force as of 1 July 2021. As a part of the package, the new concepts of intra-Community distance sales and distance sales of imported goods will be introduced, the [...]
The legitimate question nowadays is what we can expect during a tax audit if transfer pricing (tp) issues also emerge. Supposing, we possess master file presenting our group, our local file is available, and – if selected method for analysing prices triggered its need – we also have [...]