Financial and International Taxation

Our specialist tax team assists banks, banking groups, brokerage firms, leasing companies and insurance companies to navigate their own particular tax and VAT problems, to avoid the major pitfalls and to optimize their opportunities. In this sector, in particular with regard to accountancy and taxation, requirements often significantly differ from regulations in other sectors.

We provide assistance in the following areas:

• opinions on specific transactions or the interpretation of legal provisions;
• EU-related legal interpretations, tax planning;
• financing arrangements between corporate group members (international tax planning, capital market products, structured treasury products, cash pooling, investment funds);
• Business re-structuring and rebranding (transformation into a multi-profile bank);
• outsourcing;
• taxation and introduction of remuneration schemes, review of insurance plans;
• interest paid abroad (e.g. in respect of syndicated loans), taxation of dividends, reduction of withholding tax burdens in respect of international investment services;
• clarification of taxation issues in connection with new services and products;
• preparation of requests for binding conditional tax assessment and agreement with the competent authorities.

In addition to issuing opinions (during due diligence and tax review procedures) the group identifies areas which companies treat differently from the valid legal regulations, and areas where the companies pay taxes unnecessarily, i.e. where tax savings may be achieved. Also, during investigations performed by the tax authority, we keep in close contact with our clients and provide help in managing the problems and findings arising, preparing notes and appeals or in representing the company when under tax authority review.

Our group provides services primarily in relation to direct tax matters corresponding to cross border transactions, with special respect to tax advice about state aid and direct tax rules of the Hungarian and that of the EU legislation for foreign direct investors.

The main advisory areas are as follows:

• advisory on investment related state subsidies and tenders co-financed by the European Union;
• advisory on opportunities provided by the development tax allowance; advice on the (re)shaping of international corporate structures;
• complex advisory services in connection with special cross border transactions (e.g. transformations, acquisitions, etc.);
• issuing opinions on international transactions for the Hungarian investments of foreign companies and the foreign investments of Hungarian companies;
• advisory services in connection with the shaping of international corporate structures; submitting binding ruling requests with the Hungarian authorities issuing tax opinions on the contracts and documentation linked to the various international transactions;
• tax controversy and tax litigation services in relation to cross border transactions and their full support in lieu of KPMG legal services in Hungary both before the national and before the international courts