Corporate tax changes

By the current modification the possibility of carryforward unused losses that may be enforced for the tax base without any tax base adjustments related to the interest deduction limitation up to 50% is extended to losses incurred before 2015. At the taxpayer’s option, this rule may be applied for the tax year starting after 31. December 2021 for the first time.

The change of the legislation ensures exemption from corporate tax for trusts, trust foundations and public interest trusts, even if the beneficiaries are not only natural persons but also trust foundations established for the purpose of making a benefit to natural persons.

For group taxpayers, the cases of termination of group membership will be amended. the group membership would be ceased also in the case of liquidation, winding-up or compulsory liquidation of the taxpayer. In addition, in the case of the termination of a group corporate taxpayer or the membership of the group member, members would have to declare tax advances not from the date of termination but within 30 days of the date of the circumstance giving rise to the termination.

The tax base allowance for electric charging stations will be considered as a “de minimis” allowance regarding the tax returns submitted after 31. January 2022, and the special rules for using and handling of the tax base allowance related to the installation of electric charging stations will be slightly simplified.