Hungary in International Tax Planning

Preface . List of statutory law references .Current rates relevant to tax liability . PART ONE: INTRODUCTION . Chapter 1. Hungary: a focal point of investments in Central Europe 1.1. Location, population, and legal and tax infrastructure 1.2. Hungary in a Central European context 1.3. Economic climate budgetary and tax policy 1.4. Historical background: transition from a centrally planned to a viable functioning market economy Chapter 2. Legal environment 2.1. Foreign investment law, immigration and residence in Hungary, labour law 2.2. Accounting framework: principles, bookkeeping, reporting and presentation, publication 2.3. Financial law 2.4. Legal sources 2.5. Company and tax law background the tax system in brief Chapter 3. Business associations 3.1. Choice of form 3.2. Comparability with EU company law directives 3.3. Rules applicable to all business associations (formation, management) 3.4. Capital maintenance 3.5. Transformation of business associations 3.6. Consolidation, holding activities 3.7. Acquisitions PART TWO: CORPORATE AND INDIVIDUAL INCOME TAXATION Chapter 4. Taxation of resident corporations 4.2. Statutory principles and their application 4.3. Taxpayers 4.4. Corporate tax base 4.5. Comparability with EU Parent - Subsidiary and Merger Directives 4.6. Tax rates, advance corporate tax, withholding tax 4.7. Tax allowances 4.8. Corporate income tax highlights Chapter 5. International corporate tax issues under domestic law 5.1. Tax identity of business organizations under corporate tax law 5.2. Calculation of corporate tax payable by permanent establishments of foreign enterprises 5.3. Calculation of corporate tax payable by foreign enterprises without permanent establishments 5.4. Unilateral rules on the exemption of foreign income and foreign tax credit 5.5. Tax planning opportunities available to foreign enterprises Chapter 6. Individual income taxation 6.1. Concept of taxable income, calculation of income tax liability 6.2. Schedular taxes 6.3. International income tax issues under domestic law 6.4. Domestic and international tax aspects of deferred compensation 6.5. Income tax planning opportunities Chapter 7. Compulsory social insurance contributions and similar charges 7.1. System of social insurance contributions 7.2. Social security implications for the outsourcing of teaching activities PART THREE: INDIRECT TAXES, TAX ADMINISTRATION Chapter 8. VAT principles 8.1. Structure of VAT 8.2. VAT planning Chapter 9. Local taxes 9.1. Statutory framework 9.2. Sample calculation 9.3. Tax planning example: concept of negotiated services for local trade tax purposes Chapter 10. Tax administration 10.1. Rationale underlying the tax administration law 10.2. Judicial approach to enforcing substanceoverform in tax matters 10.3. Antifraud measures PART FOUR: TREATY POLICIES, ANTIAVOIDANCE LEGISLATION, TAX COMPETITION Chapter 11. Treaty practice 11.1. Main features of income tax treaties 11.2. Antiabuse measures in an international tax context 11.3. Tax planning opportunities in a treaty context Chapter 12. Assessment of the tax system from an international and EU perspective 12.1. Acquis communautaire and the Hungarian tax system 12.2. Illegal state aid and harmful tax competition List of Hungarian treaties (at 31 December 2002).