A Kft. does not gain substance from its entry in the register alone. What matters is whether the activity, decisions, documents and payments form a coherent picture in everyday business.

The activity must fit the company

During tax registration, the activities actually carried out are recorded, among other things. With a registered-office provider, information about the provider and the agreement may also be relevant. A company address therefore does not replace actual business operations.

Decisions must be economically understandable

EU anti-tax-avoidance rules link certain structures to economic reasons and economic reality. For CFC situations, the directive refers, for example, to personnel, equipment, assets, premises and essential functions. This does not create a rigid checklist for every Kft.; the business model and the responsibilities actually carried out remain decisive.

Banking and accounting reflect everyday business

Payments, invoices, agreements and accounting should match the stated activity. The size of an office is not decisive; what matters is whether the business connection remains understandable.

Cross-border questions require an individual assessment

Residence, management, the place of activity and relationships with other countries may require an individual legal or tax assessment. This assessment is the responsibility of the relevant independent partner lawyers or partner tax advisers.