Hungary Tax News
ECJ: Swedish legislation on dividend tax relief in relations with third countries is compatible with EC law – details
ECJ: Advocate General finds Dutch withholding tax on outbound dividends incompatible with EC free movement of capital – details
ECJ: Advocate General holds German switch-over provision for low-taxed passive income of foreign PEs incompatible with EC Law – details
ECJ: Previous Austrian rules discriminating dividends received from third countries are compatible with free movement of capital under grandfathering clause – details
International tax conference on CCCTB held in Berlin
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details
Parliament adopts new rules on minimum tax
Commission announces in depth investigation regarding Hungarian taxation of intra-group interest
Revised Commentary on Article 7 of OECD Model released
ECJ: temporal effects of judgment in Meilicke against Germany should not be limited – details
Company tax regimes of Swiss cantons exempting foreign profits incompatible state aid under EU-Switzerland Agreement
Final Report on Improving the Resolution of Tax Treaty Disputes
ECJ: hearing in case regarding Dutch withholding tax on outbound dividends
EU Commission requests Italy not to apply a withholding tax on dividends paid to Netherlands parent companies
EU Commission requests Italy to implement the Interest and Royalties Directive correctly
Report on Attribution of Profits to PEs released
Advance rulings for transfer prices
EU Commission progresses infringement actions against Member States for discriminatory taxation of outbound dividends
ECJ holds French withholding tax on outbound dividends incompatible with freedom of establishment
ECJ: previous UK ACT regime regarding outbound dividends compatible with EC fundamental freedoms (ACT IV GLO) – details
Treaty between Iceland and Hungary enters into force
European Commission requests Belgium, Italy, Luxembourg, Netherlands, Portugal and Spain to terminate discriminatory taxation of outbound dividends
European Commission refers Italy and Luxembourg to ECJ for not implementing Directive amending EC Parent-Subsidiary Directive
European Commission decides that Luxembourg's preferential tax regime for 1929 holding companies constitutes incompatible state aid
Tax law reform adopted for 2006 and 2007
European Commission requests Belgium to terminate discriminatory taxation of inbound dividends
European Commission requested Spain to end infringement to the EC Parent-Subsidiary Directive concerning the use of anti-abuse measures
Government plans tax increases and expenditure cuts to improve budget balance
Tax amendments for 2006 and beyond
Iceland and Hungary signed a first-time income tax treaty on 23 November 2005. Further details of the treaty will be reported subsequently.
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