
05/02/2025
Trump's Unilateral Tax Retaliation: Hungary has recently found itself in a precarious position within the global tax landscape. Some years ago, the country lost its tax treaty with the U.S., leaving its businesses unprotected against potential unilateral tax increases under Section 891 of the U.S. Internal Revenue Code. This development places Hungary among the jurisdictions most vulnerable to the U.S.'s retaliatory tax measures, particularly in the context of the OECD's Global Minimum Tax initiative. As a result, Hungary's role in the international tax arena is now more critical than ever, as it navigates the challenges posed by the absence of formal protections against discriminatory taxation.
The Scope of Section 891
The latest executive actions by U.S. President Donald Trump have sent shockwaves through the international tax landscape.
The latest executive actions by U.S. President Donald Trump to activate Section 891 have sent shockwaves through the international tax landscape.