International tax planning

What EY can do for you

Our international tax professionals provide leading-edge tax consultancy services for many of the world’s largest multinational companies. Our team works to deliver tangible benefits to our clients, thereby contributing to their competitive advantage.

Our local tax professional work in close cooperation with our international network to provide quick and efficient services in complex cross-border questions. Our market-leading global tax desk network — which consists of co-located teams of highly experienced professionals from multiple countries in several locations around the world — plays an important role in bringing together tax know-how from various jurisdictions for the benefit of the client.

Corporate structure and treaty qualification

There is increasing attention on the appropriate use of legal entities, both from tax authorities and business (for purposes of operational savings). Our professionals assist with tax efficiently, meeting these business and regulatory needs for legal entity rationalization. We also take into account the requirements under the multilateral instrument (MLI), such as the principal purpose test and other anti-avoidance measures, local country legislation and regulations such as withholding and capital gains taxes — while mitigating the impact on tax attributes in the different jurisdictions.

Tax operations focusing on cross-border transactions

The last few years have seen an ever increasing demand on tax departments to report on cross-border situations and transactions. Examples of this are many, such as master and local files in transfer pricing, country-by-country reporting, controlled foreign company reporting under EU Anti-Tax Avoidance Directives, and the Mandatory Disclosure Regime in the EU.

EY international tax service teams help you fully comply with these requirements and analyze and remediate the impact that these reporting obligations have on your global tax footprint.

Global minimum tax

The global minimum tax under the Pillar 2 of the OECD’s BEPS 2.0 initiative will require companies to pay tax at least at 15% effective tax rate on their income in every jurisdiction. While this does not necessarily mean that Hungarian companies will have an increased corporate income tax liability – given that besides the 9% statutory corporate income tax rate other direct taxes that can be considered as covered taxes – companies will face increased compliance requirements under the new regime. Our international tax team helps you navigating through the complex new rules with a unified approach across multiple jurisdictions.