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Summary 39 posts

Compliance audit or tax audit?

Tax authority inspection, tax audit, compliance audit – these are the terms that every taxpayer should understand. What is more, you should know the detailed rules of the tax audit and the compliance audit, as it is important what kind of protocol the tax authority review is based on.

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Transfer pricing 2024 – Record number of direct transfer pricing audits

In 2022, significant changes were made to transfer pricing and the preparation of transfer pricing documentation, with a multiplication of the fine and the introduction of a transfer pricing data reporting obligation. Please note that non-compliance with changes entered into force for the 2023 tax year could result in the imposition of multiple default penalties. Based on the experience of the past year, businesses are increasingly likely to face direct transfer pricing audits on transactions with their related parties.

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CIT and LBT calculations – important aspects to consider

The deadline for submitting and paying corporate income tax (CIT) and local business tax (LBT) for 2023 is approaching. It is not worth leaving the preparation of the CIT and LBT calculations as well as preparing the corresponding returns to the last minute. In our blog, we would like to highlight some of the key areas which require special attention when preparing these calculations.

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R&D investment can reduce extra profit tax of pharmaceutical producers in Hungary

Government Decree 317/2023 (17 July 2023) was published in the Official Journal of Hungary on 17 July 2023, amending the effective Government Decree on extra-profit taxes in several points. One significant change is that pharmaceutical companies may reduce their special tax liability for the tax year 2024 by the cost of R&D activity (investment) aimed at the purchase or production of tangible assets.

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Minimise your tax risk by business partner due diligence

Many companies only realise the importance of verifying their business partners and the existence of related documentation during a tax authority audit, when they are required to present their contracting procedure and, for certain business partners selected by the tax authority, their due diligence documentation. However, the outcome of the tax audit is often a tax authority report and decision in which the tax authority - citing certain objective circumstances and lack of due diligence - denies the right to deduct VAT included in the invoice received, and imposes a tax penalty, even though performance was duly made. This is because the legal regulations require a preliminary business due diligence procedure to ensure that the content of the invoice is authentic, i.e. that the actual performance is consistent with the invoice.

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The new form of VAT filing – eVAT M2M XML

The eVAT M2M system will become an increasingly common solution for VAT filing processes in the future. Although the eVAT M2M system offers many advantages for taxpayers and tax authorities, its implementation also poses challenges for both parties and expert support may be needed. If properly prepared and managed, eVAT communication will enable companies to meet their tax obligations more efficiently and easily. The Hungarian Tax Authority plans to start the test run in autumn 2023 and to go live in the first half of 2024.

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Permanent establishment for tax purposes

In our latest blog post on the specifics of permanent establishments, we have collected what foreign businesses should pay attention to from a tax perspective if they carry out permanent work in Hungary at fixed sites. The existence of a permanent establishment may require the establishment of a branch office or may give rise to VAT and/or corporate income tax liabilities. We will explain in detail what is meant by the so-called permanent establishment risk and what is meant by the concept of a fixed establishment for VAT purposes.

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Electronic invoicing: new rules and requirements from 2024

The digital age and the rapid expansion of e-commerce have brought about changes in taxation and invoicing as well. In December 2022, the European Commission proposed amendments to the VAT Directive as part of the \"VAT in the Digital Age\" initiative. Changes include significant amendments to invoicing rules, some of which could enter into force in 2024. Later on, e-invoicing would become mandatory for all businesses for transactions within the EU.

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Transfer pricing data to be reported in the CIT return

A draft amendment to the transfer pricing decree is now available, detailing the data that will need to be included in the corporate income tax return from 2023 onwards in relation to transfer pricing documentation in Hungary. In addition to the new administrative task, the documentation threshold value is expected to change and the number of transactions to be documented may be reduced.

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