A tényleges üzletvezetési hely szerepe az adózásban különös tekintettel a potenciális jogsértésekre

Abstract

This study aims to demonstrate the relevance of determining the place of effective management being aware of the fact that it is such a crucial problematic issue of the current international tax law that can be source of different abuses. Defining and creating a place of effective management has a highlighted importance especially in companies active in the field of holding and capital investment activities. Comparing the operative and strategic decisions of such business entities may lead to specific features irrespective of the trading or service providing nature of the involved companies. I would like to put forward my proposals based on the analysis of the different double taxation conventions, national tax legislations and national case laws and the best practices of the national tax authorities.