sep 19 2010
Hungary
Hungary Holding Company
| Topic | Details |
|---|---|
| Establishing HoldCo | |
| Are advance rulings available? | Yes |
| Are there restrictions on activities? | Generally no |
| Are there substance requirements? | No |
| Is capital duty payable? | No |
| Is there a special tax regime for holding companies? | No |
| Is there CFC or equivalent legislation? | Yes |
| Number of jurisdictions with active income tax treaties (minimum) | 65 |
| What is the effective corporate tax rate? | 19% |
| Tax Treatment of Disposal of HoldCo | |
| Is any tax payable in HoldCo country on disposal of HoldCo shares by a nonresident corporate shareholder? | Generally no |
| Tax Treatment of Payments by HoldCo | |
| Dividends: What is the (non-treaty / treaty) rate of withholding tax on dividends paid to nonresidents? | 0% (non-treaty, treaty and EU) |
| Interest: Are there thin cap limits or other restrictions on interest deductibility? | 3:1 |
| Interest: Is interest on loans to acquire subsidiaries deductible against HoldCo’s profits? | Yes |
| Interest: What is the (non-treaty / treaty) rate of withholding tax on interest paid to nonresidents? | 30% non-treaty; 0% treaty and EU |
| Liquidation payments: Is there withholding tax on liquidation payments? | No |
| Taxation of HoldCo Income | |
| Dividends: Does the foreign subsidiary have to meet any substance requirements? | No |
| Dividends: Does the foreign subsidiary have to pay tax locally? | No, if seated or resident in an EU, OECD or treaty country |
| Dividends: How are dividends taxed? | Exempt |
| Dividends: What is the required holding period? | N/A |
| Dividends: What is the required percentage ownership? | N/A |
| Gains on disposal of participations: Are capital losses deductible? | Not if gains are exempt |
| Gains on disposal of participations: Does the foreign subsidiary have to meet any substance requirements? | No |
| Gains on disposal of participations: Does the foreign subsidiary have to pay tax locally? | No, if seated or resident in an EU, OECD or treaty country |
| Gains on disposal of participations: How are gains on the sale of a subsidiary taxed? | Exempt provided certain conditions are satisfied |
| Gains on disposal of participations: Is relief available for the write-down in value of subsidiaries? | Not if gains are exempt |
| Gains on disposal of participations: What is the required holding period? | None |
| Gains on disposal of participations: What is the required percentage ownership? | 30% |
| Is joint taxation for groups available? | No |
