Hungary–MNE Tax

Americas

A regulatory tax hike on US multinationals

February 28, 2022

Daniel Bunn, Tax Foundation, discusses why a meaningful tax hike for multinational companies has already been adopted while much of the policy focus has been on proposals embedded in the Build Back Better agenda, which still has not yet made its way through the US Congress.

Africa

OECD releases third batch of transfer pricing country profiles for 28 jurisdictions: OECD→

February 28, 2022

Americas

Has the Indian tax administration removed the sheen from the ‘most favoured nation’ clause in its tax treaties?

February 22, 2022

Priyanshi Chokshi, Raghav Bajaj, and Vinita Krishnan, Khaitan & Co., analyze the ramifications of the Indian Central Board of Direct Taxes’ clarification of the applicability of the “most favoured nation” (MFN) clauses in Indian tax treaties through its February 3 circular.

Czech Republic

Italy’s new clarifications concerning VAT treatment of transfer pricing adjustments

February 1, 2022

Diletta Fuxa, Studio Associato Servizi Professionali Integrati, discusses the Italian tax authority’s December 30 release regarding the VAT treatment of transfer pricing year-end adjustments in its response to . . .

Austria

EU’s path forward on global minimum tax is under debate

January 18, 2022

EU member states are at odds on various issues related to the directive to implement within the EU the global minimum tax portion of the OECD agreement, with several members expressing concerns about key aspects in a January 17 Economic and Financial Affairs Council . . .

Asia-Pacific

OECD review of tax ruling exchange standard finds 36 countries could improve

December 14, 2021

Out of 131 countries the OECD reviewed in a 2020 peer review report released on December 14, 95 received no flags for improvement with respect to implementing the OECD minimum standard on exchange of information on tax rulings; however, 36 countries fell short, including . . .

Asia-Pacific

Mauritania becomes 141st country to join global tax ‘Inclusive Framework’

November 4, 2021

The OECD Inclusive Framework gains another member, with the northwestern Africa country of Mauritania joining as the 141st member, according to a November 4 OECD release. Mauritania is also joining the October 8 global tax pact.

Africa

Global tax talks reach ‘critical mass’ for landmark deal by tweaking details

October 8, 2021

The historic October 8 agreement on a global minimum tax and new rules for allocating taxing rights for large multinationals both firms up issues left open in the initial July statement and reflects concessions that were made to bring into the deal a few new countries, including . . .

Americas

OECD and Ireland strike tax deal as others in EU line up, developing countries shrug

October 7, 2021

Ireland announced October 7 that it is joining the OECD tax deal, cutting the holdouts down to just five nations out of the 140 in the Inclusive Framework that are scheduled to meet Friday, October 8, to . . .

Africa

Global minimum tax negotiations focus on carve-outs, EU consensus, closing deal

September 30, 2021

Negotiators are seeking to achieve final consensus on the details of the global minimum tax deal, according to September 29 comments from European Commission official Benjamin Angel, with talks centering on the terms for carve-outs and other technical aspects that might bring into the fold remaining . . .

Estonia

EU state of the union address calls for tax reforms

September 17, 2021

European Commission President Ursula von der Leyen stressed the importance of fair taxation and initiatives to expand the tax base in her 2021 state of the union address on September 15, emphasizing . . .

Europe

Corporate tax rates down 10 percentage points among OECD, G20, EU countries

September 9, 2021

The combined statutory corporate income tax rates among OECD, G20, and EU countries dropped in parallel from 2000–2021, 10 percentage points in each group, while broadly maintaining their positions relative to each other, according to a September 8 OECD tax . . .

Europe

Hungary will not agree to give up its 9% corporate tax rate to join global minimum tax – government official insists – neither at the behest of Brussels, nor Washington: Hungary Today→

August 16, 2021

Africa

Ireland, Lithuania, Hungary offer lowest tax rates for R&D, OECD study finds

August 2, 2021

An OECD taxation working paper on corporate effective tax rates for research and development (R&D) released on July 29 reports that the effective average tax rate on R&D investments in Ireland, Lithuania, and Hungary range from -2% to -4% – suggesting . . .

Africa

Profit shifting persists as corporate tax rates drop 30% in 20 years, OECD study finds

July 29, 2021

The OECD’s annual “Corporate Tax Statistics,” released July 29, reports that the statutory corporate income tax rate in 111 reviewed jurisdictions declined from an average of 28.3% in 2000 to . . .

Americas

EU continues to wrangle over global minimum tax’s carve-outs, rate

July 26, 2021

A July 21 study from the EU Tax Observatory predicts that a substance carve-out under the agreement for a proposed global minimum tax could exacerbate tax competition and would reduce by 15% to 30% the tax revenues that the EU would otherwise . . .

Americas

G20 reaffirms tax deal while EU delays digital levy, US eyes legislation

July 12, 2021

The communique issued by the G20 finance ministers at the conclusion of their July 9–10 meeting did not break substantial new ground in international tax talks, but the discussions seemed to help clear a hurdle in helping to . . .

Africa

130 nations endorse global tax overhaul, nine nations hold out

July 1, 2021

Following virtual talks between 139 nations represented in the OECD’s “Inclusive Framework,” 130 nations signed onto a detailed statement on July 1 for adopting new international tax rules, including . . .

Europe

Yellen predicts Ireland, EU will cooperate on minimum tax, but US might move first

June 16, 2021

US Treasury Secretary Janet Yellen said today that she has had constructive talks with the Irish finance minister and believes that Ireland – and the entire EU . . .

Americas

Cyprus to oppose global min tax, EU public country-by-country reporting: eKathimerini.com→

June 4, 2021

Estonia

Greece, Hungary, Iceland fall short of tax dispute resolution goals, OECD review finds

May 26, 2021

Iceland has no bilateral advance pricing agreement (APA) program in place, and Greece, Hungary, and the Slovak Republic are failing to timely resolve mutual agreement procedure (MAP) cases, according . . .

Americas

US agrees to 15% global minimum tax rate, boosting odds for Pillar 2 agreement

May 21, 2021

The US, which has been leading the push for a global agreement on a minimum corporate tax, has proposed a minimum tax rate of 15% – a concession from the 21% rate that the Biden Administration previously . . .

Europe

The UN transfer pricing manual’s guidance on IP valuation and royalty rates

May 19, 2021

New York City Economist, Dr. J. Harold McClure, discusses the latest edition of the United Nations Practical Manual on Transfer Pricing for Developing Countries, released April 27, which includes some useful observations on the nature of intangible assets, yet it has a very sparse discussion of the evaluation of intercompany royalty rates . . .

Europe

Hungary says global minimum tax would violate sovereignty, refuses to consent: Budapest Times→

April 28, 2021

Europe

Greece and Hungary join BEPS MLI to fight multinational group tax avoidance

March 31, 2021

Greece and Hungary have deposited their ratification instruments for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS MLI), the OECD announced March 30. . .

Digital Economy

CJEU confirms Polish and Hungarian progressive turnover taxes do not violate EU law

March 17, 2021

On March 16, the Court of Justice of the European Union upheld the General Court’s judgments that two progressive turnover taxes – a Polish tax on the retail sector and a Hungarian tax on advertisement revenue – do not violate EU state aid law. . .

Americas

Report estimates effective tax rates on investment in the EU member states, North Macedonia, Turkey, UK, Norway, Switzerland, Canada, Japan, and US: EU Commission→

February 19, 2021

Europe

EU Advocate General concludes that Poland’s retail tax and Hungary’s advertising tax, both based on turnover, are not State aid even though they primarily affect larger undertakings: Court of Justice of the European Union→

October 15, 2020

Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020

Belgium

Latest EU effort to make country-by-country reporting public fails

December 3, 2019

Davide Anghileri of the University of Lausanne, Switzerland discusses a recent EU Council vote on a proposal to make public country-by-country reports on large multinationals . . .

Digital Economy

On turnover-based taxes and digital taxes: the EU Advocate General’s opinion in Vodafone

June 17, 2019

Leopoldo Parada of the University of Turin, Italy, discusses an EU Advocate General’s opinion issued June 13 addressing Vodafone’s challenge to the Hungarian telecommunication tax . . .

Europe

EU court addresses legality of progressive turnover taxes

June 30, 2019

Dr. Patricia Lampreave, a professor at the Instituto de Estudios Busatiles, Madrid discusses a June 27 EU General Court opinion annulling an EU Commission decision on the compatibility of the Hungarian advertisement tax with the EU State aid rules . . .

Americas

US Senate to consider Chile, Hungary, Poland, Japan, Luxembourg, Switzerland tax treaty protocols: Bloomberg Tax→

June 18, 2019

Digital Economy

EU court agrees to hear Google Ireland’s challenge to Hungarian digital services tax on advertising: Duff & Phelps Transfer Pricing Times→

June 12, 2019

Americas

EU Parliament adopts controversial report on tax avoidance and evasion

March 27, 2019

Davide Anghileri of the University of Lausanne, Switzerland, writes that the EU Parliament endorsed a report March 26 that calls out seven member states for their role in facilitating aggressive tax planning and recommends countermeasures against the US should it fail to provide FATCA reciprocity . . .

Hungary and Ireland oppose EU-wide CCCTB to harmonize taxation: Carlo Motta / European Sting→

January 9, 2018

Africa

US negotiating exchange of country-by-country tax reports with 20 more nations

August 30, 2017

The US IRS is negotiating with 20 countries to annually exchange country-by-country reporting data on large multinational firms . . .

Asia-Pacific

OECD asks for taxpayer feedback on cross-border tax dispute resolution procedures in Estonia, Greece, Hungary, Iceland, Romania, Slovak Republic, Slovenia and Turkey

March 12, 2018

The OECD today asked taxpayers to provide feedback on their experiences with cross-border tax dispute resolution procedures in the following countries: Estonia, Greece, Hungary, Iceland, Romania, Slovak Republic, Slovenia . . .

Europe

Hungary to cut corporate tax rate to 9 percent next year: Jason Karaian / Quartz→

November 26, 2016

See: Quartz. More: RTE, Financial Times

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Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin