Hungary has implemented new controlled foreign company (CFC) rules as required under the EU Anti-Tax Avoidance Directive (Council Directive (EU) 2016/1164). The new rules, which are effective 18 January 2017, are implemented under the Corporate Income Tax Law, while prior CFC rules under the Individual Income Tax Law have been repealed.
Under the new rules, a foreign entity or foreign permanent establishment (PE) of a Hungarian taxpayer will be considered a CFC if:
- The taxpayer directly or …