Tax Advisory

Vital information for success

Tax is no longer only about returns and deadlines. A misinterpreted transaction, incorrect VAT treatment, an international structure or a tax authority audit can directly affect cash flow, risk exposure and management decisions.

Crowe provides practical tax advisory support for medium-sized and large companies, Hungarian businesses and international company groups. Our aim is to treat tax questions not as isolated statutory issues, but as business decision situations.

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Where we add value

Corporate tax with a business mindset

We do not look at individual taxes in isolation. We consider the overall tax burden of companies, group-level operation, transactions and the control environment.

International tax and VAT coordination

Through the Crowe international network, we can support the coordination of EU, wider European and non-European tax and VAT compliance matters under a consistent professional approach.

Risk identification and decision support

We help identify, quantify and prioritize tax risks so that management receives not only a list of issues, but a professional position that can support decisions.

Connecting tax, accounting and legal perspectives

We interpret business events from a tax, accounting and - where needed - legal perspective, so that the position is practical and usable from a business standpoint.

When do clients usually contact us?

before a new transaction, investment, financing arrangement or intragroup restructuring, when a tax position is needed

when a foreign parent company, regional headquarters or multi-country group expects consistent tax treatment

when VAT registration, fiscal representation, international VAT filing or an e-commerce structure requires coordinated support

when the company is preparing for a tax authority audit or an ongoing National Tax Authority procedure needs to be managed

during M&A, due diligence, acquisition or group restructuring processes where tax risks must be addressed

when employee benefits, international mobility, personal taxation, social security or pension-related questions arise

How can we help?

Corporate and International Taxation

Our corporate and international tax advisory services are designed to ensure that tax decisions form an integral part of operational and financial planning rather than being addressed through retrospective corrections. We consider corporate income tax, the group’s overall tax position, international structures and global minimum tax requirements within their broader business context.

Tax Advisory and Tax Planning for Companies

Optimisation of Corporate Taxation and Tax Burden

We review the tax base, commonly applicable adjustment items, available tax incentives and documentation processes in relation to the principal taxes affecting the company. Our objective is not aggressive tax minimisation, but the establishment of a lawful, properly documented and commercially justifiable tax position that reduces unnecessary tax costs and tax audit risks.

Group-Level Tax Planning

For groups consisting of several companies, we assess the operational, financing, service and profit allocation arrangements between the group entities. We help identify where tax risks may arise, where control points should be introduced, and how the group’s operations can be aligned with Hungarian legislation and international expectations.

Effective Tax Rate Analysis

An effective tax rate analysis demonstrates the actual tax burden in comparison with the company’s accounting profit and identifies the items influencing that burden. ETR analysis is particularly useful for management reporting, group-level planning, investment decisions and international benchmarking.

International Taxation and Corporate Structures

Design of Cross-Border Structures

For international transactions, service delivery models, financing arrangements or operations involving multiple jurisdictions, we support the advance assessment of the potential tax implications. Our objective is to establish a structure that is commercially viable, defensible from a tax perspective and aligned with the local compliance requirements of the jurisdictions concerned.

Holding and Financing Structures

The tax treatment of holding and financing structures may directly affect the taxation of dividend, interest and other income flows, as well as the group’s cash flow position. We assess the relevant Hungarian and international tax rules, deductibility limitations, withholding tax implications and documentation requirements.

OECD Pillar Two and Global Minimum Tax

Global minimum tax rules introduce a new level of group-wide tax data collection and reporting requirements. We support companies in assessing whether their group falls within the scope of the rules, determining the data and controls required, and integrating their Hungarian operations into the international Pillar Two compliance process.

Taxation of Foreign Permanent Establishments

Where a company has a foreign presence through sales activities, projects, services or employees working abroad, we assess whether a permanent establishment may arise and what corporate income tax, VAT, payroll or administrative consequences may follow. Early analysis can help prevent retrospective tax exposures and unexpected local compliance obligations.

Indirect Taxes and International VAT Solutions

Hungarian VAT and Compliance

VAT Advisory and Risk Assessment

We provide support in determining the appropriate VAT treatment of transactions, addressing invoicing and input VAT deduction matters, and assessing exemptions, reverse-charge arrangements, chain transactions and domestic compliance issues. As part of our risk assessment services, we not only identify errors but also recommend improvements to processes, control points and supporting documentation.

VAT Registration in Hungary

Where the Hungarian activities of a foreign business, including warehousing, imports, domestic sales or other transactions, give rise to Hungarian VAT obligations, we support the VAT registration process. We assist with the preparation of the required documentation, communication with the tax authority and the establishment of ongoing compliance procedures following registration.

Fiscal Representation for VAT Purposes

Non-EU businesses are required to appoint a fiscal representative in Hungary where they intend to carry out taxable activities directly in Hungary without establishing a Hungarian branch or subsidiary. As fiscal representative, we assume joint and several liability towards the tax authority for our client’s tax obligations. We support the management of Hungarian VAT matters, VAT return preparation, communication with the tax authority and tax audit procedures, with particular attention to ensuring that the relevant obligations are fulfilled transparently and by the applicable deadlines.

Comprehensive Hungarian VAT Compliance for Foreign Businesses

For foreign businesses registered for VAT in Hungary, we support the preparation of periodic VAT returns, recapitulative statements, statutory data reporting and the management of invoicing and documentation matters. Our objective is to provide the foreign head office with a consistent, understandable and verifiable overview of its Hungarian VAT position and to ensure that local reporting obligations are fulfilled in accordance with Hungarian requirements.

VAT Audit Support

During a VAT audit, we assist with the preparation of documents, the professional interpretation of questions raised by the tax authority, the preparation of responses and the management of identified risk areas. Our support may include advance audit preparation, professional management of an ongoing audit or the implementation of subsequent risk-mitigation measures.

International VAT and EU Compliance Coordination

EU, European and International VAT Registration and Return Preparation

For companies and corporate groups operating in multiple jurisdictions, we coordinate VAT registration and return preparation requirements across the European Union, other European countries and, where required, jurisdictions outside Europe, working together with local experts from the Crowe network. This provides the central management team with a structured international compliance process supported by status monitoring, rather than a series of separate country-by-country procedures.

Group-Level EU and International VAT Compliance Management

The objective of group-level VAT compliance management is to provide transparency across multiple jurisdictions in relation to deadlines, filing statuses, data sources, responsibilities and risks. We assist in establishing standardised operating procedures, status reports and control points for financial management.

OSS and IOSS Compliance

For e-commerce transactions, the OSS and IOSS systems can reduce the administrative burden associated with country-specific registrations. However, these systems can only operate effectively where they are supported by appropriate data quality, invoicing processes and VAT rate determination. We provide professional support for registration, operation, return preparation and the establishment of related control processes.

VAT Optimisation for E-Commerce and Marketplace Structures

For online sales, platform-based operations and marketplace structures, the applicable VAT treatment may depend on the customer’s location, the movement of goods, the role of the platform and the transaction model applied. We help assess the VAT implications of the structure and prevent incorrect invoicing and multiple or unnecessary compliance obligations.

Import, Export and Customs VAT Structures

VAT and customs treatment are closely connected in import, export, warehousing and international logistics processes. We assess customs value, import VAT, input VAT deduction rights, export exemptions, documentation requirements and cash flow implications to ensure that the process is workable from both a tax and an operational perspective.

Transaction and Structural Tax Advisory

In transactions, acquisitions, corporate reorganisations and investments, tax considerations often determine the risk profile, expected return and implementation structure before the underlying decision is made. Crowe’s approach considers the transaction structure, accounting implications and compliance consequences together.

Taxation of M&A Transactions and Corporate Reorganisations

Tax Due Diligence

During a tax due diligence review, we identify the tax risks, historical compliance deficiencies and potential tax liabilities associated with the target company or transaction. We structure our findings in a format that supports management decision-making, presenting risk levels, potential financial impacts, risk-management recommendations and possible corrective actions.

Tax Planning for Acquisition Structures

The selection of an acquisition structure may affect financing arrangements, interest deductibility, dividend flows, exit opportunities and subsequent integration. We assist in developing a tax-efficient and defensible structure that is aligned with the commercial objectives of the transaction and the relevant transaction documentation.

Corporate Group Reorganisations

In connection with intra-group transformations, mergers, demergers, transfers of business units or reorganisations of functions, we support the assessment of the related tax, VAT, transfer tax, accounting and documentation implications. Our objective is to establish a lawful and implementable restructuring that is consistent with the group’s operational model.

Investment and Tax Incentive Advisory

Research and Development Tax Incentives

For research and development activities, we assess the tax opportunities that may be available based on the nature of the project, the supporting documentation and the cost structure. We assist with the preparation of the professional and financial supporting materials, internal records and decision-making documentation.

Development and Investment Tax Incentives

For major investments, we assess the availability of relevant tax incentives and the associated requirements, including eligibility criteria, timing, documentation and the expected tax impact. Our assessment considers the total tax burden of both the company and the corporate group, including the implications of the Pillar Two global minimum tax rules. Our objective is to ensure that available incentives are evaluated as part of the investment decision rather than being considered retrospectively.

Special Industry Incentives

Certain industries, investments and technological developments may qualify for specific tax, funding or financing incentives. We assist in identifying available opportunities, assessing the applicable conditions and preparing the professional materials required to support management decisions.

Tax Authority Proceedings and Dispute Resolution

In tax authority proceedings, rapid responses, a properly documented professional position and effective control over the process are essential. Our objective is to ensure that clients do not merely provide passive responses to questions raised by the authorities, but actively manage the risks, available evidence and strategic decision points throughout the procedure.

Tax Audit Support

Preparation for Hungarian Tax Authority Audits

Before a tax audit begins, we review the relevant high-risk taxes, transactions, documentation, tax return methodologies and internal processes. The purpose of this preparation is to enable the client to anticipate potential questions, supplement any missing supporting documentation and prepare for communication with the tax authority in a structured manner.

Representation During Tax Audits

During an ongoing tax audit, we support the organisation of documents, the interpretation of questions raised by the tax authority, the professional preparation of responses and the consistent presentation of the client’s position. Our objective is to ensure that the audit is managed in a controlled, properly documented and commercially transparent manner.

Tax Risk Review

A tax risk review identifies potential exposures arising from the company’s operations, transactions, tax returns or supporting documentation. Rather than presenting our findings as a theoretical list, we provide prioritised recommendations, clearly defined responsibilities and an assessment of the potential financial implications.

Support in Tax Disputes and Litigation

Appeals and Legal Remedies

Where the tax authority issues an adverse finding, we support the structured preparation of the client’s professional position, the relevant facts and the supporting legal and tax arguments. Our appeals support is intended to ensure that the client responds consistently, strategically and within the applicable deadlines, based on the available evidence and professional arguments. We support the management of tax disputes on the basis of a comprehensive assessment, with the objective of identifying the approach that is expected to achieve the most favourable practical outcome.

Why Crowe?

International network, local Hungarian expertise

The Crowe Global member firm network enables us to coordinate international tax and VAT matters with local specialists, while also taking Hungarian regulation and tax authority practice into account.

Structured advice for management decisions

We do not only provide statutory explanations. Our goal is to make the business situation, risk, deadline, responsibility and financial impact behind the tax question clear.

Strong focus on international VAT coordination

For international company groups, VAT is no longer country-by-country administration only. It is a group-level compliance and cash-flow issue. This is where coordinated support can create real value.

Request a consultation with our experts, or send us your request for a proposal

Get in touch

Frequently asked questions

Balázs Földes

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