Tax Alert | KPMG Hungary
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Tax Alert

Tax Alert

Our regular newsletter provides you with updates on the latest changes of tax and accounting regulations as soon as a new rule is being approved.

Our regular newsletter provides you with updates on the latest changes of tax regulations.


New decree on transfer pricing documentation obligations
2017-12-14 –  New issues have emerged regarding Hungary’s country-by-countryreporting obligation. Specifically, several practical questions have arisenin respect of filling in notification sheet 17T201T. In order to clarify theseissues, KPMG’s Tax practice contacted the Hungarian Tax Authority (“theAuthority”), and provides this need-to-know update on country-bycountryreporting.

New decree on transfer pricing documentation obligations
2017-11-03 – On 18 October 2017, the Ministry of National Economy (“NGM”) issued its decree on the documentation obligations for the determination of arm’s length price (“NGM Decree”), which shall enter into force on the 30th day following its promulgation. The new decree contains several changes to the provisions of the former Decree 22/2009. (X. 16.) of the Ministry of Finance on the documentation obligations in connection with the determination of arm’s length price (“Decree 22/2009”).

16CBC form available
2017-10-26 – The Hungarian Tax Authority(’HTA’) has published on its website the 16CBC form to be applied with regards to the obligation of country by country reporting (‘CBCR’), which came into force on 31 May 2017.

Hungary to Adopt Country-by-Country Reporting
2017-06-02 – On 15 May 2017, an amendment to the Act on Certain Regulations on International Administrative Cooperation in Field of Taxes and Other Charges was accepted by the Hungarian Parliament, entering into force on 31 May 2017. Our newsletter summarizes the most crucial aspects of this regulation.



New Transatlantic Privacy Shield
2016-09-16 – The new framework regulating the transfer of personal data between the EU and the U.S. has been available as of 1 August 2016.

USA-Hungary Totalization Agreement – in force as of 1 September
2016-09-02 – Almost 17 months after its domestic publication, the totalization agreement between the United States and Hungary entered into force on 1 September 2016.

EU Commission: Ireland gave illegal State aid to Apple of up to €13 billion
2016-09-01 – EU Commission claims in its decision of 30 August that Ireland granted illegal state aid in its transfer pricing rulings to Apple. The state aid which is estimated by the Commission at up to €13 billion has now been determined to be incompatible with the internal market, and must be recovered (with interest) by the Irish authorities from the Apple group. It is expected that the decision will be appealed. Please read the opinion of the experts of KPMG EU Tax Centre.

New reporting obligation of foreign employees
2016-08-26 – New provisions for the Hungarian Act on Labor Code and the Act on Labor Inspection came into force in order to introduce the provisions of Directive 2014/67/EU of the European Parliament and of the Council on the enforcement of Directive 96/71/EC into Hungarian legislation; this concerning the posting (assignment) of workers who provide services. Based on the implementation of the Directive, additional administrative obligations arise in Hungary regarding the foreign individuals who perform work activities in Hungary.

Brexit: The tax consequences of the UK referendum
2016-06-24 – The Brexit will potentially have a radical impact on the UK tax system, as European law impacts UK tax law both as regards direct and indirect taxation. Please read the opinion of the experts of KPMG EU Tax Centre.

European Union steps forward in the field of direct taxation
2016-06-23 – KPMG’s EU Tax Centre in Amsterdam has published it’s latest news on EU direct tax matters. According to this, on its meeting of June 17, 2016 the Economic and Financial Affairs Council (ECOFIN) of the EU has reached political agreement on the proposal for an anti tax avoidance directive. The ECOFIN also approved Conclusions on the work of the Code of Conduct Group during the Netherlands Presidency and held a short discussion regarding the status of the proposal for a Directive on a Financial Transaction Tax.

Amendments to the Tax Legislation in line with Law No. T/10537
2016-06-10 – The Government has published its latest tax proposal in May, which was approved by the Parliament recently and now it is waiting for the signature of the President. The Parliament accepted almost all of the previous and later modifying proposals.

Expected amendments to the tax legislation in line with draft Law No. T/10537
2016-05-10 – As you may be aware, the Government has published its latest tax proposal, according to which several changes may be expected to the current Hungarian tax legislation.

Tax allowance for those supporting Hungary’s Olympic Games tender
2016-02-12 – A new draft law has been submitted to the Hungarian Parliament that, if enacted, would amend the Hungarian corporate income tax law regarding certain donations. The draft law provides that companies making donations towards the preparation of an offer to host the Olympic Games in Budapest would be able to qualify for a tax allowance.

EU: New anti-tax avoidance package focused on corporations
2016-01-28 – The European Commission today unveiled new measures to address corporation tax avoidance. The EC presented an anti-tax avoidance package that includes two legislative proposals addressing certain anti-base erosion and profit shifting (BEPS) issues and non-public country-by-country (CBC) reporting as well as a common approach to tax good governance towards third countries and recommendations to address treaty abuse.

Belgium: “Excess profit” tax advantages to be recovered from multinationals
2016-01-11 – The European Commission today announced it has concluded that selective tax advantages granted by Belgium under its "excess profit" tax regime are illegal under EU state aid rules. The EC's investigation showed that the regime derogated from normal practice under Belgian company tax rules and the "arm's length principle."



EU: Draft “anti-BEPS” directive, addressing corporate tax planning and evasion
2015-12-17 – The Council of the European Union released details of a possible draft EU directive, addressing certain “anti-base erosion and profit shifting” (anti-BEPS) initiatives. The issues addressed concern certain international aspects of the proposal for an EU “common consolidated corporate tax base” (CCCTB), and reflect issues that are directly related to the OECD’s BEPS project.

EU: Directive on automatic exchange of tax rulings, APAs
2015-12-08 – The European Commission (EC) today announced that the European Council adopted a directive aimed at improving transparency on tax rulings—including advance pricing arrangements (APAs)—given by EU Member States to companies concerning how certain specific taxation issues will be addressed.

OECD: Text of BEPS final recommendations
2015-10-26 – The Organisation for Economic Cooperation and Development (OECD) today issued a final package of reports in connection with its action plan to address base erosion and profit shifting (BEPS), together with a plan for follow-up work and a timetable for implementation.

EU: “Tax rulings” in Luxembourg, Netherlands deemed illegal state aid
2015-10-21 – The European Commission today announced a decision that Luxembourg and the Netherlands granted selective tax advantages to two multinational corporate entities, and as such, these “tax advantages” are illegal under EU state aid rules. The EC concluded that the tax rulings granted by the tax authorities in Luxembourg and in the Netherlands artificially lowered the tax paid by the companies in the respective jurisdictions.

Summary: Expected changes for 2016 to the tax legislation
2015-10-20 – The Hungarian government on 13 October 2015 submitted proposals for certain tax law changes to be enacted for 2016. Among the measures proposed are changes to the rules concerning how individual taxpayers comply with their tax return filing requirements. (Previous Tax Newsletter)

EU: Automatic exchange of information, cross-border tax rulings and APAs
2015-10-06 – EU finance ministers today agreed to introduce provisions for the automatic exchange of information on cross-border tax rulings—the latest development concerning the European Commission’s initiative to address tax avoidance and harmful tax competition. Detailed provisions to be included in a directive are expected to be finalized before the end of 2015, so the exact content of the new rules will not be known until that time.

Expected changes for 2016 to the tax legislation
2015-05-18 – In the Tax Alert we summarize the expected changes to the tax legislation.

An in-depth investigation has been launched into Hungarian advertisement tax procedures
2015-03-16 – In our current newsletter we inform our clients about the in-depth investigation which has been launched into Hungarian advertisement tax procedures.

Significant changes have been introduced to the new Trade Control System (EKAER)
2015-03-06 – In our current newsletter we summarize the major changes of the new Trade Control System (EKAER).

Donations to films, sports and performing arts
2015-01-19 – From 2015, a proportion of corporate income tax is allowed to be offered to artistic performance organizations, film makers and certain sports bodies.

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