Tax in Hungary

CMS

CMS specialises in advising clients on the VAT implications of new atypical products, portfolio transfers and the tax aspects of M&A. It is also regularly involved in tax litigation and assists clients with criminal cases related to tax fraud. The firm generates mandates from clients in the banking, insurance, real estate and consumer goods sectors. Senior counsel Eszter Kálmán is experienced in state aid and international tax matters, and she is a distinguished member of the European VAT group, which is an association of independent VAT specialists. Senior associate Judit Kresz advises on Hungarian and international income tax, state aid and transfer pricing issues.

Practice head(s):

Eszter Kálmán

Other key lawyers:

Judit Kresz

Key clients

Viagogo

British American Tobacco

Eon

Cosmo Consult

Crown Packaging

Infineon Cegléd

Papier Mettler

Work highlights

  • A cross-border London and CEE team advised Liberty Global, the world’s largest international cable business, on the Hungarian (and Czech and Romanian) aspects of Vodafone’s €18.4bn acquisition of Liberty Global’s European assets.
  • Regular tax advice to OTP Mobil related to the operation and future development of the Simple mobile app.
  • Advising SRF Limited on all legal, state aid and tax aspects of its greenfield investment in Hungary.

DLA Piper

DLA Piper's tax group acts for clients operating in the technology, real estate, energy and automobile sectors. Ákos Becher and Levente Torma co-head the practice, which offers a full tax advisory and litigation service. It particularly specialises in tax structuring of complex M&A and reorganisations, taxation of financial instruments, employee remuneration schemes, transfer pricing, VAT and EPPC.

Practice head(s):

Ákos Becher; Levente Torma

Key clients

Harman Becker Automotive (Samsung Group)

Synopsys Global Kft.

MFB (Hungarian Development Bank)

Work highlights

  • Advising Harman International’s Hungarian manufacturing entity on the tax matters and questions arising with respect to the cross-border merger implemented. Also advised Harman International’s Hungarian financing entity on the proper implementation of a complex, cross-border restructuring.
  • Assisting MFB Bank in taxation related matters regarding the note issuance of MFB focusing on withholding tax related matters.
  • Represented SYNOPSYS Global Kft., Subsidiary of Synopsys Group in a significant tax dispute concerning the applicability of the royalty withholding tax regime to cost sharing arrangements as well as the Hungarian accounting treatment of R&D costs.

Hegymegi-Barakonyi and Partner Baker & McKenzie Attorneys-at-Law

Hegymegi-Barakonyi and Partner Baker & McKenzie Attorneys-at-Law's 'approachable' team is experienced in tax disputes before Hungarian authorities and European courts. It also advises on the tax aspects of M&A and corporate income tax, as well as audits, VAT, customs and transfer pricing issues. Gergely Riszter is noted for his expertise in tax issues associated with establishing various financing and licensing structures through Hungarian vehicles.

Practice head(s):

Gergely Riszter

Testimonials

‘We have a special tax case and B&M is supporting us in that. Professionally up to date, clear strategical thinking. ’

‘Approachable, good communication, thinking on all aspects of the issue.’

Work highlights

  • Reviewed the local applicability of a Court of Justice decision concerning VAT base reductions. The firm prepared a tax analysis of local refund opportunities in light of the -decision and set out a practical implementation plan for the client.
  • Performed a due diligence review of a real estate holding company that a client is looking to buy and provided advice to the client to ensure the share deal is implemented in a transfer tax neutral manner.
  • Represented a client in a VAT audit by the Hungarian tax authority.

Jalsovszky

Jalsovszky fields a 'well trained team', which is 'absolutely focused on the customer's need', and is jointly led by Pál Jalsovszky, Tamás Fehér and István Csővári. The group is highlighted for its tax litigation work, as well as its strengths in tax structuring and the tax aspects of corporate transactions and financing mandates. Clients include Hungarian and international corporates operating in the telecoms, construction, energy and consumer goods sectors.

Practice head(s):

Pál Jalsovszky; Tamás Fehér; István Csővári

Testimonials

‘Very well trained team, absolutely focusing on the customer’s need.’

‘Jalsovszky’s team is very professional, kind, has a good sense of humor – which is important. We got always fast answers to our questions from the team.’

Key clients

Vodafone Magyarország Zrt.

PORR Építési Kft.

adidas Budapest Kft.

Krakvet Marek Batko

CREA-TAX Pénzügyi-, Adótanácsadó és Szolgáltató Kft.

220volt Magyarország Kft.

TAW s.r.o

Magyar Cukor Zrt.

Banzai Cloud Zrt.

Szabadics Zrt.

Work highlights

  • Designing an innovative tax efficient ESOP (employee stock option plan) scheme and organization for Banzai Cloud, in order to grant shares to its own employees through.
  • Representing Vodafone Magyarország before the Hungarian courts in a dispute concerning the special telecoms tax and transfer pricing.
  • Representing PORR Építési Kft. in court and successfully representing the client before the ECJ (C-292/19) concerning a request to refund VAT on unenforceable claims.

Nagy és Trócsányi Ügyvédi Iroda

Nagy és Trócsányi Ügyvédi Iroda has an excellent reputation in tax litigation. It also advises on tax structuring and planning, where it works with KPMG on the Hungarian law aspects of transactional tax, audits and general financial advisory matters. Orsolya Kovács acts for a range of clients in tax administrative procedures and litigation. Péter Nagy is the key figure for tax planning.

Practice head(s):

Orsolya Kovács; Péter Nagy

Testimonials

‘First of all, the international, complicated and high value lawsuits. Significant language skills, huge professional experience and knowledge are their greatest strength. Their invoicing is appropriate. In my opinion their service is excellent.’

Dr. Péter Nagy – his strengths are his huge professional experience, factual knowledge, significant litigation practice and him being strong-minded. He is a go-to lawyer. Dr. Orsolya Kovács – Her strengths are her thorough knowledge and precise document editing.’

Key clients

KPMG

Work highlights

  • Advising a Hungarian food retail chain in connection with VAT issues and representing them in tax litigation.

Vámosi-Nagy Ernst & Young Law Office

Vámosi-Nagy Ernst & Young Law Office regularly represents multinational companies in tax authority investigations, audits and other tax disputes. Its team also demonstrates strengths in VAT matters; it implemented an innovative structure concerning VAT refunds and reimbursement on specific agreements in the pharmaceutical sector, which was referred to the European Court of Justice. Clients include corporates from the pharmaceuticals, financial services, telecoms, energy, automotive and retail sectors. Szabolcs Vámosi-Nagy leads the team, which includes associates Gergely Séra and Daniel BajuszPéter Vaszari is another key name.

Practice head(s):

Szabolcs Vamosi-Nagy

Other key lawyers:

Daniel Bajusz; Gergely Séra; Peter Vaszari

Testimonials

‘Very professional level of analysis and always in time frame reporting subject to scope of work agreed.’

Young and well-educated/knowledgeable staff with strong mentality and straight ahead approach for decision making

‘Deep, practical knowledge of Hungarian and international tax regulations. Client focused approach -the explanations and analyses provided are comprehensive to non-tax experts as well. The team includes a great number of ex-authority officials with deep knowledge and understanding of authorities’ internal processes in practice’

Work highlights

  • Advised leading retailers on challenging the Hungarian retail surtax on EU conformity grounds and represented one of them before the European Court of Justice.
  • Developed and implemented an idea for VAT refunds for pharma entities. The firm is now representing one of them before the European Court of Justice.

Deloitte Hungary

Deloitte Hungary's tax team in Budapest specialises in tax and transfer pricing disputes and proceedings before the Hungarian tax authorities, administrative courts and the Supreme Court. It also supports clients in developing preventive internal control processes and in tax authority enforcement and payment facility proceedings. Mihály Harcos is the main point of contact.

Practice head(s):

Mihály Harcos

Testimonials

The team is diverse, synergistic and efficient. The team members’ unique strengths and qualities are thoughtfully combined in order to achieve the best possible results with respect to each and every mandate. The team is highly innovative, not only technology-wise, but also with regard to its approaches and solutions applied in resolving the most complex issues.’

Mihaly Harcos is a remarkable professional. His problem solving and courtroom advocacy skills are unmatched among his peers. His meticulousness and innovative approach tend to result in exceptional work products. He also appears to be a great team leader.’

KCG Partners Law Firm

KCG Partners Law Firm has a strong focus on tax planning, risk advisory work and investigations. It is routinely mandated on cross-border structuring and tax-focused advice in relation to corporate transactions, financial investments, employee stock ownership programs and transfer pricing. It is the only Hungarian representative of Ally Law, a global network  providing various legal services to corporations and a member of Expatland Global Network, which assists expats and foreign clients on a range of legal and financial issues. Eszter Kamocsay-Berta and Gabriella Gálik are the lead partners.

Practice head(s):

Eszter Kamocsay-Berta; Gabriella Gálik

Testimonials

‘Eszter Kamocsay-Berta stands out for her recognised expertise, straightforwardness and credibility. She has built a strong team of tax professionals. ’

‘ KCG Partners is one of the best prepared and proactive law firm I have ever worked with and definitely the best value for money. Their professional knowledge, ideas and approach toward solving issues have always impressed me and that is why I have chosen them as a business partner.  They are very responsive, effective and proactive when solving even quite complex issues. Their negotiation skill is also admirable. They are growing constantly on a very competitive market and they have a solid reputation in the Hungarian market.’

Key clients

LEGO

MKB Bank

OTP Bank

SUNTEC INDUSTRIES

Work highlights

  • Assisting LEGO in VAT and corporate income tax matters in relation to the transfer of ownership of real estates and infrastructures to the Hungarian State and the Local Municipality.
  • Advised MKB Bank on employment and corporate aspects of this precedent-setting employee share plan valued at €73m. The employee share incentive plan brings tax benefits for the employees and tax savings for the employer, and allows for the introduction of new corporate structures and governance.

Lakatos, Köves and Partners

Lakatos, Köves and Partners is praised for its 'top-quality service, flawless technical support and continuous commitment'. It is a go-to for international clients, for whom it provides support on tax issues connected with establishing businesses in Hungary, as well as day-to-day operational matters. The group also advises on M&A deal structuring, VAT, investigations and the application of double tax treaties and tax reliefs. Balázs Kántor heads up the practice.

Practice head(s):

Balázs Kántor

Testimonials

‘The tax team of LKT offers a top-quality service, flawless technical support and advice, strong reactivity and continuous commitment.’

Balázs Kántor produces outstanding work and demonstrates very strong commitment. He’s a deep thinker, and has good technical and analytical skills, but does not lose sight of the pragmatic side. The advice he provides is to-the- point and makes sense from a business perspective.’

I worked extensively with Balázs Kántor (counsel of the firm) and found him to be very fast in reacting to the client’s request and always very prepared, precise and responsive.’

‘All the partners, associates I have worked with had a proven business mindset, they are open to look beyond the requirements, and look at the problems in a holistic way.’

Key clients

Soulbrain

Carepark Pty. Ltd.

Trimble

Threebond

Deutsche Bank Hungary

Indotek

GLL Real Estate Partners GmbH

Mid Europa – Waberer’s

Commonwealth Bank of Australia

Bank of Utah

AFO Aircraft (NZ) Ltd.

Avolon

Hong Kong Aviation Capital

Credit Suisse AG

GE Capital Aviation Services (GECAS)

GE Japan Corporation

Accipiter

Aviation Capital Group

BNP Paribas

DVB Bank

Bank of Tokyo Mitsubishi

KfW IPEX-Bank

Industrial and Commercial Bank of China

CCB Leasing

FPG

Air Canada

Citigroup Global Markets Limited

ING Bank N.V.

J.P. Morgan Securities plc

Aeroflot

Adey Innovation Limited

Work highlights

  • Acted as Hungarian legal advisers to the Joint Lead Managers on the issue by Hungary (the “Issuer”) of (i) €1bn in aggregate principal amount of 1.125 per cent. Notes due 2026 (the “2026 Notes”) and (ii) €1bn in aggregate principal amount of 1.625 per cent. Notes due 2032 (the “2032 Notes”) in April 2020.
  • Advised the South Korea-based firm Soulbrain (to be located in the Tatabánya Industrial Park) on the tax aspects of the acquisition of a development site from the state-owned National Industrial Park Management and Development Company.
  • Continuous tax advice to Deutsche Bank Hungary, including the drafting of a Hungary Tax Guide for the Client and advising on the liability of Deutsche Bank as paying agent.

LFB – László Fekete Bagaméry

LFB – László Fekete Bagaméry is a boutique practice supporting clients in tax audits and tax disputes before Hungarian courts. On the non-contentious side, it also advises on customs and excise matters with additional niche expertise in special tax, such as the Hungarian advertising tax. The team also advises on the tax aspects of M&A deals. Tax litigator Zoltan Titusz Fekete and Gáspár Bagaméry are recommended.

Practice head(s):

Zoltán Titusz Fekete

Other key lawyers:

Gáspár Bagaméry

Testimonials

‘In the field of tax, LFB is one of the best firms, and again, a great alternative to any large corporate firms or advisory companies’

In addition to their in-house legal and tax expertise, they work closely together with accounting. customs and excise and other similar, highly specialised experts. So, they can provide assistance with even the most complex tax problems.’

‘Their understanding of the industry, their clients and international/cross-border tax issues enables them to handle very complex cross-border matters.’

Key clients

Pannonia Bio

Havas Media

Alexandra Group

Aquarius Group

TransLexWork

REGIO Jaték

Ipcenter.at / eduPR GmbH

Belden Duna Kábel

Scepter Tatabánya Kft

Digital Media and Communications Zrt

Talajerő Kft.

Doctor 24 Group

LP Portfolió Kft.

Istenhegyi Géndiagnosztika

Work highlights

  • Advise Alexandra Group, one of the largest Hungarian publishing conglomerates with publishing houses, bookshops and other relating operations on course of tax audits and tax litigations, and in every tax related matter of their daily operation.
  • Advising Doctor 24 Group, the largest private health care service providers in matters relating to VAT planning, structuring of ownership interest, local business tax planning, and other tax issues.
  • Assisting Pannonia Bio Zrt with tax planning ad tax structuring relating to investments in Hungary and abroad (including complex international structures) and tax audits, and also advise them in certain accounting matters.

Réti, Várszegi and Partners PwC Legal

Réti, Várszegi and Partners PwC Legal's team, which has 'excellent knowledge' of the tax market, is known for its experience of representing clients in tax litigation in the Hungarian administrative courts and European courts, including the ECJ. As part of the wider PwC network, the practice also benefits from additional audit, accounting and business advisory expertise. Managing partner Zoltán Várszegi and Dániel Kelemen are the primary litigators.

Practice head(s):

Zoltán Várszegi; Dániel Kelemen

Testimonials

‘Efficient communication, to the point and openness regarding the establishment of strategies.’

‘the ability to synthesize important aspects of the case, to anticipate the reaction of the opposing party and the courts and last but not least, knowledge of English.’

‘The team has excellent knowledge and such a “best practice” how to approach specific taxation issues with tax authorities.’

‘Since the legal has a close connection and collaboration to our tax advisors, we as customer can enjoy the result of this synergy.’

Key clients

Glencore Agriculture Hungary Kft.

Cargill Takarmány Zrt.

Eurasia Logistics Kft.

Henkel Magyarország Kft.

Work highlights

  • Represented Glencore Agriculture Hungary in front of the European Court of Justice, resulting in a landmark decision regarding the Hungarian tax investigation practice.
  • Successfully represented a large food manufacturing company in a customs litigation case regarding the classification of one of its products.
  • Successfully represented Henkel Magyarország in an excise licenses customs litigation.

Szecskay Attorneys at Law

At Szecskay Attorneys at LawRóbert Dezső has a strong track record representing clients in complex tax litigation against the Hungarian Tax Authority. As an all-round multilingual tax specialist, he is sought after by German, English and French-speaking clients.

Practice head(s):

Róbert Dezső

Key clients

Balobau Kft

Motoflywear Ltd.

Snohetta Insbruch GmbH

Budapesti Ingatlan Nyrt.

Sodexo

Irontrade Hungary Kft

Work highlights

  • Advising Motoflywear on corporate tax, VAT and customs structuring for their new products.
  • Represented Irontrade Hungary in multi-year, complex litigation that dealt with questions of Hungarian customs law, finally being successful before the Supreme Court.
  • Providing Budapesti Ingatlan Nyrt with ongoing support with regards to all tax aspects, including the company’s successful transformation into a corporate tax free real estate investment trust.

Wolf Theiss Faludi Erős Ügyvédi Iroda

Wolf Theiss Faludi Erős Ügyvédi Iroda stands out for its wide-ranging tax offering, with it advising both corporate clients and individuals on high-value litigation, M&A and structuring, transfer pricing and personal income tax services. János Pásztor is the lead figure, handling day-to-day tax issues and advice on the implementation of employment share schemes on behalf of international clients.

Practice head(s):

János Pásztor

Testimonials

We could ask every question we had in mind and received proper answers.’

Key clients

BASF

BorsodChem

Enlight

Hemisphere International Properties

International Flavors & Fragrances

TA Associates

Work highlights

  • Advised BorsodChem in relation to the self-revision of local taxes on the ground that the local taxes levied by the local municipality violate constitutional principles, and representation of BorsodChem in court proceedings before the first instance tax court and the Hungarian Supreme Court.
  • Advising Hemisphere International Properties on the insolvency and restructuring of Kika and Leiner furniture traders with an important position on the markets of the CEE.
  • Advising TA Associates on its investment in Netrisk, Hungary’s leading online independent insurance marketplace.