Moore Hungary: There are almost two weeks left for the decision on the choice of group corporate taxation
Companies wishing to establish a group corporate tax entity for the 2025 tax year can submit an application to the National Tax and Customs Office by November 20. This form of taxation can significantly ease the tax and administrative burdens of corporate tax, it is also advisable for taxpayers with affiliated businesses to think about the possible advantages and decide to take advantage of the opportunity – warns Moore Hungary.
The essence of group corporate taxation is that the members of the group taxpayer are considered as one taxable person in terms of corporate tax, which also means that the members’ independent corporate tax liability ceases from a corporate tax point of view, while they are still considered independent taxpayers in terms of other types of tax.
It can have many advantages
Group corporate taxation can have many advantages. On the one hand, based on the special loss accrual rules for group taxpayers, the negative tax base generated by any group member during the operation of the group can reduce the group corporate tax base, even in the tax year of creation, with the restrictions contained in the Tao Act. As a result, the corporate tax payable for group members with a positive tax base can also be reduced.
Another advantage is that the transfer price correction rules do not have to be applied to the calls between group members, and there is no need to prepare a transfer price register for them, so significant administrative cost savings are also available.
Finally, group taxation can also be beneficial in terms of taking advantage of individual corporate tax benefits. When using certain tax benefits, the group is considered a single taxpayer, so it is sufficient if one group member can meet the conditions related to the benefits (for example, in the case of the development tax benefit).
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