The provisions of the corporate taxpayer group is applicable from 1 January 2019, and despite the short preparatory period, more than 200 company groups have so far taken advantage of this opportunity in 2019. This possibility will be open again from 1 November to 20 November 2019.
The corporate taxpayer groups provide certain tax benefits. One of the most important advantages is that the losses of group members will become usable within the group: the tax base (i.e. the amount of the positive tax bases of the group members) may be reduced by the amount of the loss carried forward from negative tax bases of the group members up to 50% of the current year profit, which represents a potential tax saving opportunity. Furthermore, transfer pricing rules are generally not applicable to the group members’ internal transactions, the related transfer pricing documentation is not required, and individual tax allowances can be utilized at the group level.
By Eszter Kamocsay-Berta, Founding and Managing Partner, KCG Partners Law Firm