Successful international business operations require careful tax planning and compliance with the applicable legislation.
Our experts provide support in the tax assessment of cross-border transactions, intra-group transactions, expansion into foreign markets and international tax structures. Our aim is to ensure that our clients' decisions are properly substantiated and that the related tax risks can be appropriately managed.
How can we help?
In the field of international taxation, we provide professional support in assessing the tax implications of transactions, business structures and corporate groups. We assess, among other things, the tax treatment of cross-border transactions, the potential creation of a permanent establishment, double taxation matters, as well as related documentation and compliance requirements.
Tax Analysis of International Transactions
We assess the tax implications of cross-border transactions and provide support in determining the appropriate tax treatment of the transaction. We assist with the practical application of the relevant Hungarian, EU and international rules.
International Structures and Expansion
We provide tax advice in connection with entering foreign markets, establishing new corporate structures, setting up foreign companies or permanent establishments, and assessing the tax implications of intra-group operating models.
Identifying Tax Risks
We identify tax risks arising from international operations, assess their potential impact and develop practical recommendations to mitigate risks and support regulatory compliance.
Permanent Establishment and Economic Presence
We assess permanent establishment and economic presence issues arising in connection with foreign activities, as well as the resulting tax and compliance obligations.
Tax Treaties and Double Taxation
We assist with assessing matters relating to the application of international tax treaties, the avoidance of double taxation and the tax treatment of cross-border income.
Tax Authority Rulings and Professional Opinions
We provide support in the professional analysis of complex international tax matters, the preparation of tax authority ruling requests and other applications, as well as the development of detailed tax opinions.
CROSS-BORDER TRANSACTIONS
The Structure of a Transaction Also Matters for Tax Purposes
The tax implications of an international transaction are not determined solely by the countries of the parties involved. The contractual terms, place of performance, actual circumstances of the activity, payment structure and the relevant intra-group relationships may also be significant.
International tax matters should therefore be assessed already at the stage of structuring the transaction. Appropriate advance analysis can help identify tax risks, determine the expected obligations and reduce the need for subsequent corrections.
International Taxation in Practice
International tax matters often involve several types of taxes, countries and legal systems at the same time. Appropriate treatment therefore requires not only knowledge of the individual rules, but also their practical coordination.
Entering Foreign Markets
We help identify the tax implications of entering a foreign market and provide support in assessing tax matters related to the new operating model.
Intra-Group Transactions
We assess the tax aspects of cross-border transactions between related parties, as well as the obligations and risks arising from the applicable rules.
International Tax Compliance
We support our clients in identifying, interpreting and fulfilling tax obligations arising in connection with international operations.
PROFESSIONAL SUPPORT
We Look Beyond the Individual Transaction to Its Entire Tax Environment.
When assessing international tax matters, we aim to consider the applicable rules together with the actual economic and legal environment of the transaction. This can help identify areas requiring particular attention from a tax or compliance perspective.
We provide professional support ranging from addressing individual questions to analysing more complex international structures, as well as developing the related documentation and professional position.
Ongoing Professional Support in International Taxation
Changes in international operations, the emergence of a new market, a new contractual arrangement or a restructuring of the corporate group may give rise to new tax matters. We therefore support our clients not only in relation to individual transactions, but also on an ongoing basis in establishing and reviewing international tax processes.
Our aim is to ensure that our clients have a clear understanding of the tax obligations and risks arising from cross-border operations and can make their business decisions on the basis of appropriately considered tax implications.
Frequently Asked Questions
We have compiled the questions most frequently asked about international taxation, cross-border transactions, entering foreign markets, permanent establishment matters and double taxation.
When should you consult an advisor on an international tax matter?
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It is advisable to assess the tax aspects already when preparing an international transaction or entering a foreign market. Advance analysis can help identify potential tax obligations and risks and contribute to establishing an appropriate business and tax structure.
What does it mean if a permanent establishment may arise as a result of foreign activities?
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The creation of a permanent establishment may result in tax and other compliance obligations arising in the foreign country in connection with the activities carried out there. The issue must always be assessed based on the nature of the activity and its actual circumstances.
How can double taxation be addressed?
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The tax treaty between the countries concerned and the applicable Hungarian rules may play an important role in addressing double taxation. Based on an assessment of the circumstances of the transaction, it can be determined which provisions may apply to eliminate or mitigate double taxation.
In which country can profits from a cross-border service be taxed?
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When determining the taxing rights over profits from services, it is primarily necessary to assess in which country the business is tax resident and whether a permanent establishment relevant for tax purposes is created in the other country.
What documents may be required when assessing an international tax matter?
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Depending on the nature of the transaction, documents may include, among other things, contracts, invoices, intra-group agreements, descriptions of business processes and information on the operations of the companies concerned. The documentation required for the analysis is always determined based on the specific characteristics of the transaction.
Do You Have Questions About International Taxation?
Are you planning to enter a foreign market, structuring a cross-border transaction, or looking to assess the tax risks of an existing international structure? We can assist with assessing the transaction or operating model from a tax perspective, identifying the related obligations and developing an appropriate solution.
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