Taxation of influencers: under the table or above board?

Holding companies and other so-called "letterbox companies", which mainly collect passive income without a real economic presence, have been in the crosshairs of the European Union for quite some time. The draft directive published by the European Commission on 22 December as a kind of Christmas present could complete this process.
Tax-efficient forms of remuneration, serving at the same time, as a means of motivating management have never been more popular. And the range of options available for doing this has expanded this summer to include what’s known as a Special Employee Co-Ownership Program (“KMRP” in Hungarian), a vehicle that can be used for in certain situations that cannot be handled in the context of an Employee Part-ownership Program, MRP. In addition, KMRPs are an excellent vehicle for implementing management buyouts.
For many, the summer months bring to mind sunny beaches, mouth-watering Mediterranean cuisine, colourful buildings along Portuguese streets, and cities that offer memorable cultural experiences... Yet few are aware that, beyond drawing in tourists, because of their tax systems, popular holiday resorts are also attractive destinations for affluent, well-to-do foreigners - often for periods of time longer than that of a mere summer adventure.
At the beginning of April, a new OECD standard came into force, by virtue of which tax authorities will be better placed to monitor the activities of companies registered in tax havens and to access their key financial data. Although it remains to be seen how the Hungarian Tax and Customs Administration (NAV) will use this information, several popular tax minimisation strategies may be at risk.
First reports under DAC6 were due recently from those who are parties to a cross-border transactions. Concurrently, at the last possible moment, the Hungarian Ministry of Finance published a Guide on certain issues related to the fulfilment of the reporting obligation. It is advisable, in particular, for accountants, consultants, lawyers and banks to carefully study this 38-page document, as any of them could easily fall within the scope of the reporting obligation.
The law is constantly in flux. While many people may find this intimidating, for us it’s precisely what makes it so exciting. We’d like to share this attitude with businesspeople and managers, and with those who just have an interest in business law, in the form of a regularly updated blog that discusses the latest tax law and commercial law issues in an accessible style. Feel free to send your questions and suggestions for topics you’d like us to cover to blog@jalsovszky.com.