Hungarian Parliament Considering Changes in CFC and PE Rules

As previously reported, a draft bill was submitted in the Hungarian parliament on 13 October 2020 that includes measures for additional relief for businesses in light of the COVID-19 pandemic. Further to the measure reported, the draft bill also includes certain important corporate tax measures regarding controlled foreign companies (CFCs) and permanent establishments (PEs).

With regard to CFCs, it is provided that certain exemptions from the CFC rules may not be applied in relation to fore…