Cross-Border Wealth Structuring Between Turkey And Hungary: Trusts, AMFs, And Tax Efficiency

I. Introduction

With an amendment to its Civil Code in 2013, Hungary introduced the concept of the Trust—originally rooted in the Anglo-American legal system, into its domestic legal framework, marking a significant development in the field of asset planning. Subsequently, in 2019, the introduction of the Asset Management Foundation (AMF) added a further hybrid structure, offering property owners an additional mechanism for asset protection and for ensuring the orderly intergenerational transfer of family wealth. The Trust and Asset Management Foundation structures offer alternative investment options in Hungary to potential foreign investors.

Investors who seek to mitigate risk by avoiding the concentration of assets in a single structure frequently prefer institutional arrangements such as Trusts and AMFs. Moreover, in order to prevent potential conflicts and disputes that may arise within families through traditional inheritance law instruments—such as wills