Business taxation 4.
Corporate Income Tax - Controlled foreign company
Dear readers, in this blog about the Hungarian business taxation I provide you a general overview about the Hungarian tax regime. This blog does not provide tax or legal advisory. This blog deals with the Corporate Income Tax (Controlled foreign company).
A company is deemed to be a controlled foreign company (CFC) if a Hungarian tax resident ultimate beneficial owner owns or controls at least ten percent participation in the foreign company or more than fifty percent of the company’s revenue derives from Hungarian source and the effective payable foreign corporate income tax of the company is less than ten percent of the gross pretax profit and the company is not registered in the EU or OECD countries or those jurisdictions that have double tax treaty with Hungary and there is no such an owner of the company that listed in recognized stock exchange and owns at least twenty five percent of the company, all over the tax year.