Information Broshure of The Tax Advisor Expert Group Ltd. (Hungarian: Az Adotanacsado Expert Group Kft.) We render professional tax services and offer complex business solutions related to taxation.

1. THE TAX ADVISOR
EXPERT GROUP LTD.
„The real disillusionment comes when the tax refund eufophoria passes
and one realises that it’s just his or her own money that has been
reimbursed to some negligible extent”

2. Mission
Statement
We are dedicated to contributing to the success of the Hungarian enterprises
through our professional knowledge. We believe that only client-oriented and
committed work, as well as quality services can create a real value. Our purpose
is to render practical and clear solutions to our clients, so that to enable them
making informed and well-structured decisions.
The Tax Advisor Expert Group Ltd.| Company reg. no. 01-09-307804 | Kunhegyes u. 4. , 1116 Budapest, Hungary

3. Contents ❑ Our firm……...……………………………………………………….….
❑ Our experts.…………………………………………………………….
❑ Why choose us……………………………..............................
❑ Our clients………………………………………………………………..
❑ Memberships.…………………………………………………………..
❑ Services…………..………………………………………………………..
❑ Professional support of workflow digitalisation…...…..
❑ International taxation (general issues)….…………………..
❑ International taxation (employment)………………………..
❑ Wealth management, generational change in
leadership…………………..…………………………………………….
❑ Transfer pricing documentation services.……..……………
❑ Financial sector (business lines)..………………………….…..
❑ Financial sector (in-house tax advisory)…………..…………
❑ Real Estate Development sector…………………………..……
❑ Small and medium-sized enterprises (SMEs)…………….
❑ Start-up companies..…………………………………………………
❑ Should you hire a tax professional?.............................
❑ Contacts………................................................................
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4. Our firm
Our firm was founded in 2017. We render professional tax services and offer
complex business solutions related to taxation.
Since our inception we concentrate on providing the highest level consulting
services to our clients. We make clear, well-defined recommendations aligning
with the client’s business practices. The solutions we recommend facilitate tax
savings and help our clients effectively manage tax risks.
The assignments our experts took recently include: professional tax support of
high-value investment property sale and purchase transactions, maintenance of
such properties, preparation of advanced pricing agreement requests,
international tax planning, assistance with the tax authorities’ enquiries, dispute
resolution.
We work in close co-operation with our partners which enables us to offer
package solutions. Apart from taxation services through our partners we can
provide bookkeeping, legal, insurance, payroll, controlling, investment services,
as well as property-related services (valuation, facility management, etc). This
removes the burden of searching necessary service provider from the client.
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The Tax Advisor Expert Group Ltd.| Company reg. no. 01-09-307804 | Kunhegyes u. 4. , 1116 Budapest, Hungary

5. Our experts
Our experts possess Master’s degrees in Economics and more than 15 years of
professional experience. They have track record of employment with the Hungarian Tax
Administration, tax consultancy and financial institutions.
Our experts have a strong background in tax aspects of bank, investment and insurance
products, as well as high-value property transactions. Beside that, they gained
considerable experience in conducting tax due diligence, in numerous aspects of
international taxation, representation before tax authority and support of taxpayer with
regard to comprehensive tax audits.
Our experts are chartered tax experts, certified chartered international tax experts,
certified chartered accountants (General Business/Commerce and IFRS) licensed by the
Hungarian Ministry of Finance.
Our consultancy services are available in Hungarian, English and Russian.
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The Tax Advisor Expert Group Ltd.| Company reg. no. 01-09-307804 | Kunhegyes u. 4. , 1116 Budapest, Hungary

6. Why choose
us
❑ We provide up-to-date information and industry specific (as required by client)
newsletters on tax law amendments which assist our clients in timely preparation for
the regulation changes;
❑ We write our tax opinions in a clear and well-structured manner. We take into
consideration the client’s business practices and contribute with our recommendations
to tax risk mitigation and elimination;
❑ Due to our work experience gained in the financial industry, we have expert
knowledge in tax aspects of bank, investment and insurance products. We also are
familiar with the operational level specificities of banks and financial institutions and
can assist in the taxation-related issues induced by comprehensive regulatory
environment;
❑ Our experts can provide support in the issues related to IT and accounting, eg.
electronic invoicing and electronic archiving of documents;
❑ Contingency fees are available for our tax due diligence service which means that
the client pays fee as a percentage of the valid potential tax savings established, thus
the tax saving always exceeds the fee payable for the service;
❑ Our consultancy services are available in Hungarian, English and Russian.
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The Tax Advisor Expert Group Ltd.| Company reg. no. 01-09-307804 | Kunhegyes u. 4. , 1116 Budapest, Hungary

7. Our clients
We render tax consultancy and tax compliance services particularly to banks, investment
fund manager companies, insurance companies, shared service centers and their clients.
Just another priority area for our firm is professional tax support of small and medium-
sized enterprises (SMEs), with special regard to providing comprehensive assistance to
start-up companies.
Due to our financial industry specialisation we lend effective support to individuals in the
taxation issues related to their savings and investments (voluntary pension and health
insurance funds, insurance products, preferential tax schemes available under the
Hungarian Act on personal income tax, such as pension savings (“NYESZ-R”), long-term
investments (“TBSZ”), controlled capital market transactions (“ETÜ”)).
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The Tax Advisor Expert Group Ltd.| Company reg. no. 01-09-307804 | Kunhegyes u. 4. , 1116 Budapest, Hungary

8. Memberships
Our firm is a member of the Hungarian Association of Tax Advisors and
Bookkeeping Service Providers (“Adókamara”), as well as the Hungarian
Association of Certified Tax Experts (“MOKLASZ”).
By joining these professional bodies we place an emphasis on our dedication
to providing high quality services.
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The Tax Advisor Expert Group Ltd.| Company reg. no. 01-09-307804 | Kunhegyes u. 4. , 1116 Budapest, Hungary

9. Services
The classical tax advisory services relevant for all types of companies include, but are not
limited to:
❑ Tax Due Diligence:
Tax due diligence involves analysis of tax treatment applied in the past in respect of its
consistency with the Hungarian tax regulations in force, analysis of findings of historical tax
audits, assessing key tax risks and advising on tax risk mitigation. Usually recommended prior to
initiating a tax refund procedure (so called “health check” service), borrowing from a bank,
changes in corporate ownership structure, restructuring. Contingency fee pricing available.
❑ Tax optimisation, tax planning:
Involve analysis of potential tax credits and tax reliefs available for the client, the consistency of
the selected form of taxation with the client’s business activities, making recommendations on
optimising tax liabilities. In case of cross-border transactions we examine the tax planning
options available under the circumstances. Contingency fee pricing available.
❑ Support of taxpayer with regard to tax audits, representation before tax authorities,
support of tax appeal claims, dispute resolution:
The material and procedural part of the Tax Administration’s practices has changed
considerably since January of 2018. This affects instalment agreement requests, Advanced
Pricing Agreement (APA)-related procedures etc. We offer complete professional support in
such matters.
❑ Tax advice on high-value property transactions:
Involves advising on VAT, stamp duty, corporate income tax (CIT) issues. In case of complex
contract structures, any controversial issues we seek individual interpretations from the Tax
Administration or the Ministry of Finance. We also provide full administration with regard to
preliminary tax ruling requests.
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The Tax Advisor Expert Group Ltd.| Company reg. no. 01-09-307804 | Kunhegyes u. 4. , 1116 Budapest, Hungary

10. Professional
support of
workflow
digitalisation
Our experts assist in selecting an appropriate IT solution (digital platform) and offer
professional support beyond purely taxation issues: from set up of the workflow process,
through system testing and up to final audit.
Our services in this area include:
❑ E-archiving:
Electronic archiving is an optimal solution for dematerialising physical archives and
streamlining document workflow within a company. Documents become easily
searchable, productivity can be improved by providing instant access to information.
❑ Integration of procurement and accounts payable processes (“Procure-to-Pay”):
Integration of procurement and accounts payable processes speeds up processing of the
suppliers’ bills and reduces late payment penalty expenditures.
❑ E-invoicing:
Implementation of electronic invoicing systems is not solely a taxation issue. Even in a
small enterprise several employees process invoices which means a considerable
inherent risk.
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The Tax Advisor Expert Group Ltd.| Company reg. no. 01-09-307804 | Kunhegyes u. 4. , 1116 Budapest, Hungary

11. International tax
advisory
(general issues)
Entering an international market is a big commitment for a company which raises
numerous taxation issues. Careful thought should be given to these issues prior to
opening to external markets.
Our services in this area include:
❑ VAT registration in Hungary or in an EU state;
❑ Advice on holding company location and organisational structure recommended for
incorporation under particular circumstances of the client and also to prevent tax
leakage;
❑ Rendering tax advice on special and cross-border transactions, including M&A
transactions and restructuring;
❑ Examining taxation issues related to intangible assets, cross-order borrowing,
permanent establishments (PEs) and VAT;
❑ Providing tax opinion on the agreements to be signed with foreign partners, identifying
tax risks and making tax optimisation recommendations;
❑ Rendering tax advice on issues related to dropshipping (VAT and customs duty, VAT
registration, invoicing, advised form of taxation consistent with the company’s scope
and scale of activities).
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The Tax Advisor Expert Group Ltd.| Company reg. no. 01-09-307804 | Kunhegyes u. 4. , 1116 Budapest, Hungary

12. International tax
advisory
(global mobility)
In business practice, there is a growing number of cross-border assignments of employees
Global mobility raises multiple taxation issues of specific nature that should be solved on the
organisation level, nonetheless with consideration for the personal circumstances of the
employee affected. Such an approach mitigates the tax risks of foreign assignments and
improves employee satisfaction and loyalty.
We offer tailor-made solutions adapted to the corporate HR strategy of the client for the tax
and social insurance issues arising during foreign assignments of Hungarian employees or
domestic assignments of foreign (expat) employees, also with the regard to the followings:
❑ Planning and optimization of the tax obligations of employees and their employers,
including advice on expected developments in the near future in the light of latest trends
in international taxation (OECD, EU, USA);
❑ Identification of expatriate tax residence, elimination of double taxation;
❑ Maximising employment time for social insurance purposes;
❑ Tax aspects of timing of share options;
❑ Tax aspects of FATCA;
❑ Tax compliance, including preparation and filing of annual PIT returns; filing requests for
tax ID and social security ID number issue; requests for tax residency certificates, tax
certificates, income certificates; representation of individuals before tax authority in tax
audits.
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The Tax Advisor Expert Group Ltd.| Company reg. no. 01-09-307804 | Kunhegyes u. 4. , 1116 Budapest, Hungary

13. Wealth
management,
generational change
in leadership
Generational change in leadership of small and medium enterprises (SMEs) can pose a
serious problem if the owner(s) do not pay due attention to sorting it out.
We believe that generational change in leadership can be solved only in a comprehensive
manner with an effective collaboration of experts from various fields.
As part of such collaboration our experts render the following services:
❑ With respect to establishing a trust (“bizalmi vagyonkezelés”):
Examining the tax optimisation options available under the trust structure and identifying
tax risk factors, also with regard to legal requirements;
❑ With respect to tax planning of generational change in leadership:
Identifying the tax saving options, eg. involving establishing appropriate holding company
schemes.
❑ With respect to initial public offering (IPO) on Budapest Stock Exchange:
Performing tax due diligence in case the generational change in leadership is accomplished
through going public.
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The Tax Advisor Expert Group Ltd.| Company reg. no. 01-09-307804 | Kunhegyes u. 4. , 1116 Budapest, Hungary

14. Transfer pricing
documentation
services
The Hungarian transfer pricing documentation requirements changed considerably from
January 2018. The changes affect not only the form of documentation, but also methods of
calculation of arm’s length price, benchmarking requirements, etc.
Our experts are ready to offer their support in:
❑ Preparation of transfer pricing documentation (Master file and Local file format);
❑ Review of transfer pricing documentation prepared by client;
❑ Tax advice on transfer pricing requirements with regard to international trends (OECD
BEPS Action 13, EU guidelines);
❑ Preparation or review of the client’s transfer pricing policy;
❑ Representation of the client before the tax authority in course of a tax audit targeted at
transfer pricing;
❑ Preparation of Advanced Pricing Agreement request and full support during the APA issue
procedure.
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The Tax Advisor Expert Group Ltd.| Company reg. no. 01-09-307804 | Kunhegyes u. 4. , 1116 Budapest, Hungary

15. Financial sector
(business lines)
Our firm works with financial services clients providing sector specific tax assistance for
their business as usual. Our services in this area include, but are not limited to:
❑ Tax due diligence prior to credit approval or a lease contract re-structuring;
❑ Tax advice for bank clients, eg. in case of special investment products;
❑ Representation of the bank clients in the “wealth gain” investigations (“vagyonosodási
vizsgálat”);
❑ Participation in the client events held by banks as invited tax experts;
❑ Planning and optimization of the tax obligations generated by any business line;
❑ Tax advice and support for new product development or with regard to tax law
amendments (eg. related to financial transaction tax - FTT);
❑ Tax advice on day-to-day matters as well as on specific transactions (eg. VAT-liability of
the insurance fee under an open-end lease contract);
❑ Tax advice on the in-kind forms of employee remuneration (“cafeteria rendszer”)
whose regulation changes significantly from January 2019;
❑ Detailed presentation of, and if required, assistance in the implementation of the
Employee share option scheme (“Munkavállalói részvényprogram”) which is taxed
under more favourable conditions than other types of remuneration under the
Hungarian regulations.
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The Tax Advisor Expert Group Ltd.| Company reg. no. 01-09-307804 | Kunhegyes u. 4. , 1116 Budapest, Hungary

16. Financial sector
(in-house tax
advisory)
Our experts are ready to offer significant assistance not only for the business lines of our
financial services clients, but also acting as their in-house tax advisors. Our services in this
area include, but are not limited to:
❑ Drafting of recommendations for tax bills, opining on the tax bills already submitted to
the Parliament as part of co-operation within the professional organisations, such as
Hungarian Banking Association (Bankszövetség), Association of Hungarian Investment
Fund ans Asset Management Companies (BAMOSZ), Association of Hungarian Insurance
Companies (MABISZ) and others;
❑ Full administration services in the area of corporate income tax reliefs which our experts
have gained considerable experience in, such as those available for team sports,
cinematography, performing arts support. Beside that, we offer comprehensive support in
claiming energy efficiency tax relief;
❑ Optimisation of tax position within a group of companies, tax effective financing and thin
capitalization rules;
❑ Tax support of M&A, split and reorganization transactions from planning to
implementation stage;
❑ Tax optimisation related to the financial sector levy (banks, fund management companies,
venture capital fund management companies, lease companies): determining and review
of tax base calculation, tax credits and tax reliefs);
❑ Examining tax optimisation options for the financial transaction tax (FTT);
❑ Tax advice on development and launch of insurance products, preparation of client tax
summary for particular insurance products;
❑ Tax support of portfolio sale and purchase transactions.
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The Tax Advisor Expert Group Ltd.| Company reg. no. 01-09-307804 | Kunhegyes u. 4. , 1116 Budapest, Hungary

17. Real Estate
Development
sector
The fundamental common feature of all development projects is that they inherently
bear a high tax risk. In addition, when solving any tax issues arising one cannot but pay
particular attention to financing and liquitity aspects of a proposed solution.
Our experts are ready to offer you assistance in the following areas:
❑ Tax advice on the issues arising in the different phases of investment (project
preparation, construction, settlement, commercialization, sale of the project, lease
and ongoing maintenance) with special regard to VAT;
❑ Tax advice related to marketing strategy of property leasing (tenant incentives,
discounts, rebates etc.);
❑ Complex tax advice on lease and sale-and-lease-back deals, MLA contracts (VAT, CIT
etc.)
❑ Seeking individual interpretation of the tax authority or of the Ministry of Finance in
regard to complex deal structures;
❑ Filing preliminary tax ruling requests to the Ministry of Finance and assistance with
the related enquiries of the Ministry.
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The Tax Advisor Expert Group Ltd.| Company reg. no. 01-09-307804 | Kunhegyes u. 4. , 1116 Budapest, Hungary

18. Small and
medium-sized
enterprises
(SMEs)
Tax support of small and medium-sized enterprises is a priority area for our firm. Our services
aim to help SMEs bring tax effective decisions, while upkeeping their reputation with the tax
authority as transparent and fully compliant taxpayers.
Beside the above-mentioned services, our experts are ready to offer the following assistance:
❑ Examining whether the client correctly claims the SME status for taxation purposes,
❑ Tax advice on withholding tax related to intangible assets, cross-border financing, etc;
❑ Tax advice on VAT liability of movement of goods within the EU;
❑ Full administration related to set-up or widening of a VAT group;
❑ Tax advice on the VAT issues of building industry and general contractor companies;
❑ Advice on the tax and social contribution aspects of advertising campaigns and
promotions;
❑ Support of tax audits (including comprehensive audits).
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The Tax Advisor Expert Group Ltd.| Company reg. no. 01-09-307804 | Kunhegyes u. 4. , 1116 Budapest, Hungary

19. Start-up
companies
A careful tax planning in start-up companies facilitates realisation of a bigger profit and
promotes effective cash flow management. Due to tax planning the company’s loan
applications, tender bids, business reports leave more positive impression on finance
providers and information users.
Venture capitalists observe that start-up companies often have messy, irrational tax
structures which decrease their chances in the competition for financial sources.
The below-mentioned services facilitate effective solution of taxation issues:
❑ Select an appropriate tax structure
Our experts assist in selecting an optimal tax structure before incorporation with special
regard to international market entry, as well as to attracting investors, venture capitalists
and finance providers. We take an integrated holistic approach to these issues including
social insurance contribution and tender considerations.
❑ Tax issues of employee stock ownership plans (ESOPs)
ESOP is a key element of attracting and retention of highly qualified employees. Beside
that, ESOPs are often a pre-requisite of any venture capital participation. Our experts
assist in planning of the tax aspects and timing of ESOPs.
❑ Tax relief for investing in a start-up company („korai fázisú vállalkozások
adókedvezménye”)
Our experts provide advice on the terms and conditions of the tax relief available for
potential investors (business angels) in corporate income tax.
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The Tax Advisor Expert Group Ltd.| Company reg. no. 01-09-307804 | Kunhegyes u. 4. , 1116 Budapest, Hungary

20. Should you hire a tax professional?
Does your company take advantage of all available tax deductions and tax benefits? Are your business transactions always
structured in the best possible way from the taxation point of view? Are all tax risks identified in each and every case?
Did you recently have a tax audit in your company?
Has your company switched to electronic invoicing? Do you use an electronic archive for your document workflow? Did you
implement an electronic contract management system?
Are you clear on the tax law amendments for years 2018 and 2019 and their implications for your business?
Did you have a tax due diligence (“health check”) in the recent years which could help you identify potential risks and possible
methods of tax optimisation?
Is it always easy in due course of your business to classify for tax purposes the transactions/contract structures you enter in, so
that there’s no need to seek individual interpretations from authorities?
If you answered “no” to any of the above questions, we suggest you contact our firm. We will help you
solve your problem.

21. Contacts
Mr. Gábor GERMÁN +36 30 417 8984
Ms. Marina LISNYANSKAYA +36 70 433 1521
gabor.german@azadotanacsado.hu
marina.lisznyanszkaja@azadotanacsado.hu
info@azadotanacsado.hu
www.azadotanacsado.hu
https://www.linkedin.com/company/az-adótanácsadó/
The Tax Advisor Expert Group Ltd.| Company reg. no. 01-09-307804 | Kunhegyes u. 4. , 1116 Budapest, Hungary