Tax in Hungary

CMS

CMS has a full-service tax practice, which is lauded for its ‘remarkable consistency, work culture and professionalism’. It is noted for its strong capabilities in the tax aspects of M&A and real estate transactions, construction projects, VAT, income taxes, tax fraud and litigation. Its work has an interface with sectors such as insurance, aviation, manufacturing, TMT and consumer goods. ‘Commercial minded’ senior counsel Eszter Kálmán is well-versed in domestic and international tax structuring, including customs, excise tax and environmental product levy issues. Senior associate Judit Kresz also plays a key role in the team.

Practice head(s):

Eszter Kálmán

Other key lawyers:

Judit Kresz

Testimonials

‘CMS has a wide range of expertise in the tax field. The tax practice is a nice addition to the firm’s full-service offering and the team itself is made up of quite senior and reputable advisers.’

‘I would highlight the head of the tax team, Eszter Kalman. Eszter always provides high-quality advice and we rely heavily on her expertise. She is very commercially-minded and understands the complexity of risk management. She is also well aware of how and when to approach the tax authorities.’

‘Eszter Kalman was outstanding in providing legal advice as required – seems to have a good understanding of both the economy in general and the market in question.’

‘There are only a limited number of international law firms in the Hungarian market that offer tax advisory services. CMS is one of them. Whenever we had issues that involve taxation aspects, they were able to assist us in those.’

‘I’m grateful for their professionalism, their availability, the trust that I can feel that they will do their utmost best to meet our needs and the extra mile that they put in everything they do.’

‘The level of consistency in their team, work culture, and professionalism is truly remarkable.’

Key clients

Bravofly

British American Tobacco

Framatome

I squared Capital

Partner in Pet Food

Infineon Cegléd

Papier Mettler

OTP Mobil

Samsung Electronics

MOL

Hunstaman

Pepkor

Duna Szálloda Zrt

Work highlights

  • Provided VAT advice to OTP Mobil on the operation and development of the Simple mobile app. OTP Mobil is the developer of the Simple mobile app, and SimplePay integrated payment solution. The company is an independent subsidiary of OTP Group located in Budapest.
  • Advised Framatome, an international leader in nuclear energy, on a complex legal and tax due diligence as well as negotiation of the SPA, including tax warranties and indemnities formulated based on the findings of the tax DD.
  • Assisting OEM client with a major greenfield investment project in Hungary, including extensive support with state incentives. One of the largest greenfield industrial developments in Hungary.

DLA Piper Posztl, Nemescsói, Györfi-Tóth and Partners Law Firm in cooperation with DLA Piper UK LLP

DLA Piper has top-notch expertise in Hungarian and international tax and customs law, with renowned capabilities in tax planning, tax and customs litigation and transactional tax matters. Tax litigation is also an area of strength for the team, which has particular experience of advising clients in sectors such as technology, real estate, energy and automotive. The practice is jointly led by Ákos Becher and Levente TormaBalázs Sőth is experienced in tax audits and disputes and is currently representing a client before the Supreme Court of Hungary, where he previously successfully challenged the Hungarian tax authority. Péter Király leads the transfer pricing offering.

Practice head(s):

Ákos Becher; Levente Torma

Other key lawyers:

Balázs Sőth; Péter Király

Key clients

Lear Corporation Kft.

BorsodChem Zrt.

MFB Bank

Burberry Limited

Work highlights

  • Advised the Lear Corporation Hungary Autóipari Gyártó Kft.  on the process of claiming interest on delayed value added tax refunds. The scope includes the representation of the client in front of the tax authority and the court.
  • Assistance to MFB Bank in taxation related matters regarding the note issuance of MFB focusing on withholding tax related matters.
  • Assisted Burberry Ltd with its data reporting obligation in tax investigation carried out by the tax authority.

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

Hegymegi-Barakonyi and Partner Baker & McKenzie Attorneys-at-Law is a leading name in the market for multijurisdictional tax mandates and sizeable tax disputes, owing to its network of offices and expertise in local and international taxation. The practice is well-versed in VAT, transfer pricing, tax structuring and corporate income tax. Gergely Riszter primarily advises on local tax issues and structuring of investments, including implications of the establishment of various financing and licensing structures through Hungarian vehicles. On the contentious side, Tímea Bodrogi-Szabó represents clients in audits and tax disputes with the tax authority.

Practice head(s):

Gergely Riszter

Other key lawyers:

Tímea Bodrogi-Szabó

Key clients

Forever Living Products Hungary

Work highlights

  • Represented Forever Living Products Hungary in connection with a landmark case where the tax authority tried to apply its common approach regarding the taxation of the managing director’s remuneration while disregarding that the client is an MLM company where sales and marketing functions are performed by the independent distributors and not by the company itself.

Jalsovszky

Jalsovszky‘s ‘strong and professional' tax team plays a key role in significant domestic and cross-border corporate and financing transactions, and it has extensive expertise in Hungarian taxation issues. The firm has strengthened its tax offering with the addition of several senior and mid-level associates from Hungarian National Bank, Ministry of Finance and a well-known accountancy firm. Pál Jalsovszky is a highly regarded transactional tax specialist. He is supported by Tamás Fehér, who is a top name for VAT and excise tax, as well as tax disputes. Senior associate Ákos Baráti is another key figure. István Csővári left to establish Csővári Legal in May 2021.

Practice head(s):

Pál Jalsovszky; Tamás Fehér

Other key lawyers:

Ákos Baráti

Testimonials

‘Strong and professional team. Full focus on client.’

‘Akos Barati is the person we are dealing with. He is good, focused, efficient’

‘They are vey enthusiastic, enjoy their work, open to challenges. It is easy to work with them, the team is very supportive and cooperative.’

‘Tamas Feher has comprehensive capabilities and skills. Besides the very deep tax law knowledge he has expertise in court representation, very successful in front of the ECJ as well.’

Key clients

Constellation Hungary S.A.

CREA-TAX Pénzügyi-, Adótanácsadó és Szolgáltató Kft.

UNIX AUTÓ Kft.

Belváros-Lipótváros Sportközpont Kft.

MFB Zrt.

Euler Hermes

Antra ID

Work highlights

  • Advising MFB Bank and drafting its internal code of conduct regarding the Bank’s due diligence process on potential tax avoidance and profit shifting practices of its clients.
  • Representing Euler Hermes in a tax dispute for reimbursement of VAT on a bad debt portfolio.
  • Advising Staff House in a pre-exit restructuring, including an internal buyout.

Nagy és Trócsányi Ügyvédi Iroda

Nagy és Trócsányi Ügyvédi Iroda excels in acting for local and international corporates in complex tax disputes before the Hungarian tax authority and domestic courts. It is also highly reputed for tax structuring and planning, as well as transactional tax structuring. In addition to generating work from clients on a standalone basis, the firm attracts referrals through its membership of the Lex Mundi network and longstanding relationship with KPMG Hungary. The key partners are Péter Nagy and Orsolya Kovács.

Practice head(s):

Orsolya Kovács; Péter Nagy

Testimonials

‘Péter Nagy – He has a vast breadth of professional experience in tax advice, as well as top litigation skills. He is our go-to our lawyer.’

‘Orsolya Kovács – Her main areas of expertise are in tax structuring and tax disputes. She is thoroughly knowledgeable and has a lot of experience drafting documents, precisely to what the client needs.’

‘Orsolya Kovács was the partner on our engagement. She has several years of experience in tax litigation and local tax rules. She is very kind, polite and has solid experience in this field.’

‘Proactive team with the ability to explain the situation at a non-legal level.’

Key clients

KPMG

Work highlights

  • Advising a Hungarian food retail chain in connection with VAT issues and the firm is also representing it in tax litigation.

Vámosi-Nagy Ernst & Young Law Office

Vámosi-Nagy Ernst & Young Law Office particularly distinguishes itself in tax litigation and tax controversies. On the non-contentious side, it is building its presence advising on the tax aspects of restructurings and M&A. It also advises on transfer pricing and VAT refunds and reimbursements. Clients recommend Gergely Séra for his ‘varied experience in numerous types of taxation and industries.’ He focuses on handling tax litigation before the European and Hungarian authorities. Péter Vaszari is also recommended.

Practice head(s):

Gergely Sera

Other key lawyers:

Péter Vaszari

Testimonials

‘This practice is not only an excellent choice for tax litigation but also during a tax audit, tax planning or on business transactions- they apply their experience gained in the courtrooms to all those areas.’

‘Gergely has wide experience across various types of taxation and industries, which is a huge advantage to clients in a tax audit or a court case. He is always up to date with the latest improvements and trends in legislation and in local and international court decisions. He manages his team in a straightforward yet firm way, and he earns great respect from his team members.’

‘The team was great and well-assembled. Very fast problem-solving and feedback. Good availability.’

Key clients

WAE Kft.

Work highlights

  • Assisted WAE Kft. with acquiring the importing rights of the Opel brand in Hungary, Bosnia and Herzegovina, Slovenia and Croatia, which was the largest automotive deal of the CEE region.
  • Advising several new clients on rules regarding the new retail surtax.
  • Developed and implemented a structure for VAT refunds for pharma entities. The firm is now representing one of them before the European Court of Justice.

Deloitte Hungary

Deloitte Legal Göndöcz and Partners Law Firm‘s team, which comprises of partner Mihály Harcos and senior associate Diána Takács, focuses on tax litigation and represents clients before the Hungarian tax authorities, administrative courts and the Supreme Court. Harcos is experienced in tax cases involving the application of EU law and routinely advises clients within the real estate, energy and telecoms sectors. The ‘outstanding‘ Takács also provides complementary support in matters concerning corporate income tax, local business tax and private taxation.

Practice head(s):

Mihály Harcos

Other key lawyers:

Diana Takács

Testimonials

‘They are extremely reliable, have a high level of expertise and are therefore very unique.’

‘I would like to mention Diana Takács. Her expertise is outstanding.’

KCG Partners Law Firm

Clients are impressed with KCG’s 'value-for-money services', 'professional knowledge', 'admirable negotiation skills' and 'solid reputation in the market'. The practice handles tax optimisation for corporate reorganisation and group structuring, transactional tax planning, investment-related tax planning,  employee/executive compensation tax schemes, transfer pricing, tax investigations and litigation. Eszter Kamocsay-Berta and Gabriella Gálik are the partners to note.

Practice head(s):

Eszter Kamocsay-Berta; Gabriella Gálik

Testimonials

‘KCG’s lawyers have important skills like critical thinking, creativity and high problem-solving skills.’

‘Based on my past experience, KCG Partners is one of the best prepared and proactive law firms 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 their negotiation skill is also admirable.’

‘My main point of contact is Gabriella Gálik whom I consider a brilliant lawyer and who is helpful and smart. It is not quite common to meet such an enthusiastic lawyer, who is well prepared from a professional point of view who strives to provide the highest standard even under a lot of pressure and to come up with a solution that is beneficial for the client.’

Key clients

MKB Bank

OTP Bank

SUNTEC INDUSTRIES

Work highlights

  • Advising Suntec Group on VAT and other taxes concerning contractual matters with special regard to the closure of the Hungarian business of the group.
  • Advised MKB Bank on a ground-breaking employee share plan valued at €2.8m p.a.

Lakatos, Köves and Partners

Lakatos, Köves and Partners provides ‘top-quality service with flawless technical support and advice’. It acts for a wide range of international clients operating in Hungary, historically in the energy, financial services, automotive and telecoms sectors. The team advises on the tax aspects of M&A and finance transactions, international tax planning and VAT matters. Practice head Balázs Kántor has ‘good technical and analytical skills’ and is the lead lawyer on all corporate tax and structuring mandates.

Practice head(s):

Balázs Kántor

Testimonials

‘The tax team at LKT offers a top-quality service, flawless technical support and advice, strong reactivity and continuous commitment. Balázs Kántor and his team provides valuable and personalised support throughout our projects.’ 

‘I work with Balázs Kántor on tax matters. Balázs provides outstanding work and very strong commitment. He’s very thorough, has good technical and analytical skills but does not lose sight of the pragmatic side. The advice he provides is spot-on and makes sense from a business perspective.’

‘Reliable team, meet deadlines and expectations of the client.’

Key clients

Soulbrain

Trimble

Deutsche Bank Hungary

Indotek

Citigroup Global Markets Limited

ING Bank N.V.

J.P. Morgan Securities plc

Aeroflot

European Climate Foundation

Toyo Ink

Fidelidade

Work highlights

  • Advised the South Korean firm, Soulbrain (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 and on all other legal aspects of its Hungarian operation.
  • Acted as Hungarian legal tax advisers to Citigroup Global Markets Ltd on the instructions of the Joint Lead Managers in connection with the issue by Hungary of (i) €1m in aggregate principal amount of 1.125 per cent Notes due 2026 and (ii) €1m in aggregate principal amount of 1.625 per cent. Notes due 2032 in April 2020.
  • Advised Indotek on the acquisition of various properties (mainly shopping malls) in Budapest including structuring, tax advice and financing. The firm also advised Indotek on the acquisition and management of distressed asset portfolios with a focus on non-performing corporate loans in Hungary and the Balkans.

LFB – László Fekete Bagaméry

Founded by Andras Daniel Laszlo, Zoltan Titusz Fekete and Gáspár Bagaméry, LFB – László Fekete Bagaméry‘s ‘highly skilled‘ team impresses with its ‘second-to-none expertise, whilst remaining down to earth and accessible.’ Fekete and Bagaméry have notable expertise in tax audits and litigation. On the non-contentious side, senior associate Linda Danicz advises on the tax aspects of domestic and cross-border corporate, commercial and property transactions. Clients also turn to the firm for advice on the Hungarian advertising tax.

Practice head(s):

Zoltán Fekete; Gáspár Bagaméry

Other key lawyers:

Linda Danicz

Testimonials

‘The three founding partners are highly skilled and very professional, their expertise is second to none, yet they are down to earth and accessible. Their combined expertise in both legal ad tax issues is extremely useful. The firm’s international capacities are impressive. They seamlessly manage our cross border transactions and disputes.’

‘Andras Laszlo’s technical skills and legal expertise commands respect both at the negotiating table and in the courtroom. He is bright, a quick thinker with great communication skills.’

‘Zoltan Titusz Fekete has tremendous experience in the field of tax investigations and tax lawsuits. He is a tactical mastermind, always a step ahead of the tax authority, who was a great help with a very substantial tax investigation.’

‘Gaspar Bagamery’s commercial mindset and business-oriented approach is a great combination with Andras’ legal expertise and litigation experience.’

‘The firm is a single-stop service, which makes our life very easy and comfortable. We deal with legal and tax matters within one firm, so there is no need the duplicate work. The team is small but very efficient, they deliver good work in short deadlines.’

Key clients

Pannonia Bio

Doktor 24 Group

Istenhegyi Géndiagnosztika

LP Portfolio

Alexandra Group

Belden Dunakábel

Orbico Hungary

Red Lemon

Havas Média

Work highlights

  • Advising Alexandra Group, one of the largest Hungarian publishing conglomerates with publishing houses, bookshops and other relating operations in course of tax audits and tax litigations, and in every tax related matter of their daily operation.
  • Advising Doctor 24 Group, one of the largest private health care service providers in matters relating to VAT planning, structuring of ownership interests, local business tax planning, and other taxes.
  • Supporting Pannonia Bio, one of the largest European bioethanol manufacturer in connection with tax planning ad tax structing relating to investments in Hungary and abroad (including complex international structures); tax audits as well as related accounting matters.

Réti, Várszegi and Partners PwC Legal

Réti, Várszegi and Partners PwC Legal works closely with audit, tax and business advisory powerhouse PwC to provide a full range of services to clients. It is regularly instructed in tax controversy mandates and is notably prominent in complex cases heard before the European Court of Justice and Constitutional Court of Hungary. Managing partner Zoltán Várszegi is principally active in disputes in the energy, mining, government, utilities and telecoms sectors. In addition to handling local tax disputes, Dániel Kelemen has a significant advisory practice, which encompasses VAT, digital tax and transfer pricing.

Practice head(s):

Zoltán Várszegi; Dániel Kelemen

Testimonials

‘Prompt and efficient communication.’

‘This practice pays special attention to the clients, there is a strong intention to deeply understand the client’s needs as well as the background and motivation. Their professional experience provides a strong basis to set up appropriate strategies and their perseverance makes these strategies successful.’

‘Individuals representing this team are highly-qualified, experienced professionals who are open to new challenges, while managing to provide clarity and focus in important moments. They are responsive, glad to answer the questions and make serious efforts to reach the desired progress. I specifically mention Mr Dániel Kelemen, whose leadership qualities make this team a great one.’

Key clients

VITERRA Hungary Kft.

Telenor Hungary Zrt.

Gránit-Pólus Fejlesztési Kft.

Pólus Irodaház Ingatlanhasznosító Kft.

Cargill

Work highlights

  • Successful representation of VITERRA Hungary in several high-profile tax and customs disputes – including representation based on previous representations in front of the European Court of Justice
  • Advising Telenor Hungary on a local taxation issue including civil law, regulatory and taxation matters and consultations with the competent ministries.

Szecskay Attorneys at Law

Szecskay Attorneys at Law has a strong track record acting for local and foreign clients in complex tax and customs litigation. Non-contentious work is also a key component of the practice; employment-related tax work has been a notable area of activity for the firm, specifically in the context of EU and non-EU clients’ employees working from abroad as a result of COVID-19 lockdowns. Róbert Dezsõ is a well-regarded litigator and the firm's main tax partner.

Practice head(s):

Róbert Dezső

Testimonials

‘Professional knowledge and precise work’

‘Excellent competence and full attention.’

Key clients

Balobau Kft

AMD Europe Kft.

Snohetta Innsbruck GmbH

Budapesti Ingatlan Nyrt.

Deutsche Lufthansa AG

NOKSEL

AEV Europe Kft

Zebra Neo 2014 Kft.

Work highlights

  • Continuing to advise Budapesti Ingatlan Plc. on all aspects of the company’s tax affairs, including the company’s successful transformation into a corporate tax free “real estate investment trust” and various contemplated foreign investments.
  • Representing Noksel Celik Boru Sanayi, a major Turkish manufacturer from the steel pipe industry, in a customs-related dispute with its former Hungarian customs representative. The dispute involves disputes with both the customs representative and the customs authority.

Wolf Theiss Faludi Erős Ügyvédi Iroda

Wolf Theiss Faludi Erős Ügyvédi Iroda‘s team is experienced in handling tax issues arising from M&A and restructurings. Beyond undertaking transactional work, it also advises on transfer pricing, employment share schemes and wealth planning for private high-net-worth clients. Tax litigation is another driver of work. The group is highlighted for its knowledge of sector-specific tax issues, particularly in the energy and manufacturing industries. Practice head János Pásztor is ‘a true star‘.

Practice head(s):

János Pásztor

Testimonials

‘Great quality of work and exceptional communication with the clients.’

‘Janos Pastor is a true star. It is a pleasure to work with him.’