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János Karczub

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...
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New CIT incentive for electric battery investment projects

As of 2024 a new, significant corporate income tax (CIT) incentive is introduced for investment projects aiming at construction of electricity storage facilities (i.e. batteries).
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Accounting for and taxation of dividends

In Hungary the resolution on dividend is taken once a year when the financial statements are approved and the company\'s supreme body decides on the amount and payment of the dividend. Under the effective legal regulations, untied retained earnings supplemented by the after-tax profit from the previous financial year may be disbursed as dividend.

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Foreign VAT refund - The Court of Justice of the EU comes to the aid of taxpayers

The Court of Justice of the European Union (CJEU) has ruled (C-746/22) that a Hungarian rule which does not allow foreign taxpayers to submit their VAT refund documents even in the second instance procedure is not in line with the EU law. The CJEU found that the Hungarian legislation infringes the principle of VAT neutrality and the principle of effectiveness, as it prohibits taxpayers from providing the additional information requested by the first-tier tax authority in an appeal to the second-tier tax authority.

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Importance of SME qualification – Micro-, small and medium sized enterprises?

The correct SME qualification (micro, small or medium-sized) has a particular importance for Hungarian companies when applying for certain EU tenders or reviewing the eligibility for corporate income tax (CIT) base decreasing items or CIT credits, but also for determining whether a given company is subject to innovation contribution or not. The Hungarian SME qualification has to be carried out based on a complex methodology prescribed by the corresponding act, and the SME status has to be indicated in the annual CIT return.

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