As previously reported, a draft bill was submitted in the Hungarian parliament on 13 October 2020 that includes measures for additional relief for businesses in light of the COVID-19 pandemic. Further to the measure reported, the draft bill also includes certain important corporate tax measures regarding controlled foreign companies (CFCs) and permanent establishments (PEs).
With regard to CFCs, it is provided that certain exemptions from the CFC rules may not be applied in relation to foreign companies established in a non-cooperative jurisdiction. Non-cooperative jurisdictions for this purpose will be issued through a decree, which is expected to follow the EU list of non-cooperative jurisdictions. With regard to PEs, the definition of PEs is updated in order to comply with the latest OECD standards on the definition of PEs for tax treaty purposes.
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