Opinion of the Advocate General — ECLI:EU:C:2019:728
Date: 2019-09-12
Language of the case: Hungarian
Subject matter: Freedom to provide services
Procedure: Reference for a preliminary ruling
Origin: Hungary

Translation C-482/18 — 1 
Case C-482/18  
Request for a preliminary ruling 
Date lodged:  
24 July 2018 
Referring court:  
Fővárosi Közigazgatási és Munkaügyi Bíróság (Budapest 
Administrative and Labour Court, Hungary) 
Date of the decision to refer:  
13 July 2018 
Applicant:  
Google Ireland Limited 
Defendant:  
Nemzeti Adó- és Vámhivatal Kiemelt Adó- és Vámigazgatósága 
(National Tax and Customs Authority, Central Tax and Customs 
Department for Major Taxpayers, Hungary) 
  
Közigazgatási és Munkaügyi Bíróság (Budapest Administrative and Labour 
Court, Hungary)... 
In the administrative court proceedings concerning taxation between Google 
Ireland Limited (..., Dublin, Ireland)..., the applicant, and the Nemzeti Adó- és 
Vámhivatal Kiemelt Adó- és Vámigazgatósága (National Tax and Customs 
Authority, Central Tax and Customs Department for Major Taxpayers) (... 
Budapest, Hungary).., the defendant, this court has issued the following 
Decision 
This court orders a stay of proceedings and makes a reference to the Court of 
Justice of the European Union for a preliminary ruling on the following questions: 
1) Should Articles 18 and 56 of the Treaty on the Functioning of the European 
Union (‘TFEU’) and the prohibition on discrimination be interpreted as 
precluding a Member State’s tax legislation in which the penalty provisions 
require, for breach of the obligation to register for the purposes of an 
EN 
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advertisement tax, the imposition of a fine for failure to comply, the total 
amount of which, for companies not established in Hungary, can be 2 000 
times greater than the amount of the fine for companies established in 
Hungary? 
2) Can the penalty described in the previous question, which involves a 
markedly large sum and is punitive in nature, be considered as capable of 
discouraging service providers who are not established in Hungary from 
providing services in that country? 
3) Should Article 56 TFEU and the prohibition on discrimination be interpreted 
as precluding legislation under which, for undertakings established in 
Hungary, the obligation to register is satisfied automatically, without making 
an explicit application, through the allocation of a Hungarian tax 
identification number as part of the process of registering with the 
Companies Registry, irrespective of whether or not the undertaking 
publishes advertisements, whereas for undertakings that are not established 
in Hungary but that publish advertisements in that country it is not satisfied 
automatically, and instead they have specifically to comply with the 
obligation to register, and can be subject to a specific penalty if they fail to 
do so? 
4) If the answer to the first question is in the affirmative, should Article 56 
TFEU and the prohibition on discrimination be interpreted as precluding a 
penalty such as the one at issue in the main proceedings, imposed for breach 
of the obligation to register for the purposes of an advertisement tax, in so 
far as the aforesaid legislation may be contrary to that article? 
5) Should Article 56 TFEU and the prohibition on discrimination be interpreted 
as precluding a provision under which the decision to impose a fine on an 
undertaking established abroad is final and enforceable from the moment 
when notice of it is served, and the decision may be contested only through 
judicial proceedings in which the court may not hold a hearing and only 
documentary evidence is admissible, while fines imposed on undertakings 
established in Hungary may be contested in an administrative procedure and, 
moreover, the judicial proceedings are not restricted in any way? 
[6)] In view of the right to good administration established in Article 41(1) of the 
Charter of Fundamental Rights (‘the Charter’), should Article 56 TFEU be 
interpreted as meaning that this obligation is not satisfied where the fine for 
failure to comply is imposed in the form of a daily fine, meaning that the 
amount of the fine is tripled while the service provider is still unaware of the 
earlier decision and is therefore unable to make good its omission before the 
imposition of the next fine? 
[7)] Should Article 56 TFEU, as read with the right to  good administration in 
Article 41(1) of the Charter, the right to be heard in Article 41(2)(a) of the 
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Charter, and the right to an effective remedy and to a fair trial in Article 47 
of the Charter, be interpreted as meaning that these requirements are not 
satisfied where the decision cannot be contested in an administrative 
procedure and where, in the administrative court proceedings, only 
documentary evidence is admissible and the court cannot hold a hearing? 
... [procedural considerations of domestic law] 
Reasons 
Background 
The applicant is a commercial company registered in Ireland, and its registered 
office and head office are in Dublin. 
In a decision ... dated 16 January 2017 the defendant imposed on the applicant an 
initial fine of 10 000 000 (10 million) forint for failure to comply, followed by a 
daily fine for failure to comply which tripled the amount of the earlier fine, 
bringing the total amount of the fine to 1 000 000 000 (one billion) forint for 
failure to comply with the obligation to register for the purposes of the 
advertisement tax laid down in Articles 7/B to 7/D of the a reklámadóról szóló 
2014. évi XXII. törvény (Law XXII of 2014 on the taxation of advertisements; 
‘the Law on the taxation of advertisements’). 
In the reasons it gave for its decisions, the defendant stated that, based on 
declarations submitted by customers, it had verified that in 2016 the applicant had 
carried on activities that were subject to the advertisement tax but had failed to 
satisfy the obligation to register on commencement of a taxable activity in 
accordance with Article 7/B(1) of the Law on the taxation of advertisements. 
The dispute between the parties 
The applicant has brought an action before the administrative courts against the 
decisions of the Tax Authority, requesting that the decisions be annulled. 
The applicant considers that the imposition of a fine for failure to comply under 
Article 7/B of the Law on the taxation of advertisements due to failure to register 
with the Tax Authority is contrary to Articles 18 and 56 TFEU, that it is easier for 
Hungarian companies to satisfy the requirements of the said Law, and that there is 
a disproportionate difference in the penalties that may be imposed on them. 
The applicant notes that EU law prohibits not only direct discrimination between 
individuals on grounds of nationality ― see the judgments in Eurowings 
Luftverkehr (C-294/97), [Berlington Hungary and Others] (C-98/14), [Säger v 
Dennemeyer] (C-76/90) and Van Binsbergen v Bestuur van de Bedrijfsvereniging 
voor de Metaalnijverheid [33/74] ― but also any measure adopted by a Member 
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State that may produce a discriminatory outcome (indirect or covert 
discrimination, C-134/93 [sic]). 
The applicant notes that, with regard to the penalties that may be applied by a 
Member State, there is settled EU case-law to the effect that administrative 
measures and sanctions must not go beyond what is strictly necessary for the 
objective pursued, and a penalty must not be so disproportionate to the gravity of 
the infringement that it becomes an obstacle to the freedoms guaranteed by the 
European Union. The case-law recognises that, while sanctions are a matter for 
Member States, they must exercise that power in accordance with EU law and its 
general principles, and, consequently, in accordance with the principle of 
proportionality ― see the judgments in Commission v Greece (C-210/91), 
Louloudakis (C-262/99) and Commission v Greece (C-375/95). 
Referring to the judgment in Reisebüro Broede v Sandker (C-3/95), the applicant 
emphasises that, where Member States wish to introduce a measure that may give 
rise to indirect discrimination, they must comply with the requirements laid down 
in that judgment: in other words, the measure must be applied in a 
non-discriminatory manner; it must be justified by the general interest; it must be 
suitable for securing the attainment of the objective which it pursues; and it must 
not go beyond what is necessary to attain the objective in question. 
In the applicant’s opinion, the imposition of the fine for failure to comply under 
Article 7/B of the Law on the taxation of advertisements is contrary to EU law, 
given that the applicant is subject to more disadvantageous requirements than 
companies incorporated in Hungary that provide the same services. The fine for 
failure to comply ― which is at least 20 times, but may be as much as 2 000 
times, the amount of the fine imposed on domestic companies ― is seriously 
detrimental to companies incorporated in other Member States and may also 
amount to a restriction on freedom to provide services within the European Union. 
The applicant states that, in the present case, the amount of the fine for failure to 
comply goes beyond what is strictly necessary to attain the desired objective and 
that, given the short period of time between the decisions, the fact that these are 
final and enforceable once notice of them has been served, and that it is not 
possible for foreign taxpayers to contest the fine in an administrative procedure or 
to have a hearing as part of court proceedings, the national legislation does not 
satisfy the requirements set out in the Reisebüro Broede v Sandker judgment. The 
fine for failure to comply that has been imposed is therefore discriminatory, and 
the establishment of tax laws that disadvantage foreign firms cannot be justified 
by arguing that the objective of the laws is, moreover, to ensure the unity of the 
tax system. 
The applicant states that the fine for failure to comply would constitute a 
restriction on freedom to provide services within the European Union even if the 
amount of the fine that can be imposed on foreign companies were not to be 
deemed discriminatory when compared with companies incorporated in Hungary 
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that provide the same services. The applicant points out that in [Berlington 
Hungary and Others,] C-98/14, the Court of Justice held that Article 56 TFEU 
requires not only the elimination of all discrimination on grounds of nationality 
against providers of services who are established in another Member State, but 
also the abolition of any restriction which is liable to prohibit, impede or render 
less attractive the activities of a service provider established in another Member 
State where it lawfully provides similar services. The applicant concludes that the 
amount of the fine for failure to comply that has actually been imposed on it, 
amounting to one billion forint, is sufficient to make the provision of services in 
Hungary less attractive, and that there is no justification for the restriction. 
The applicant states that non-resident taxpayers are essentially also at a 
disadvantage from a procedural standpoint, in that Article 7/B(4) of the Law on 
the taxation of advertisements stipulates that decisions to impose fines are final 
and enforceable from the moment when notice of them is served, whereas, under 
Article 172 of the az adózás rendjéről szóló 2003. évi ХСII. Törvény (Law XCII 
of 2003 on general tax procedures; ‘the Law on general tax procedures’) fines 
imposed on domestic taxpayers can be contested in an administrative procedure 
under Article 136(1) of the Law on general tax procedures. Moreover, in the 
administrative court proceedings provided for in Article 7/B(4) of the Law on the 
taxation of advertisements, only documentary evidence is admissible and the court 
is to reach its decision without holding a hearing, whereas domestic taxpayers are 
governed by Article 143(1) of the Law on general tax procedures, and therefore 
Chapter XX of the a polgári perrendtartásról szóló 1952. évi Ш. törvény (Law III 
of 1952 on civil procedures) applies, which contains no such restrictions. 
The applicant states that the penalty regime established by the Law on the taxation 
of advertisements is repressive and is a direct and serious breach of the right to 
property enshrined in Article 17 of the Charter. 
According to the applicant, the disputed provisions do not guarantee the subject of 
the fine a right to an effective remedy, given that decisions are final and 
enforceable from the moment when notice of them is served, that there is limited 
scope to submit evidence, and that a foreign national has extraordinarily little time 
in which to prepare properly for the proceedings and to exercise its rights. The 
Law on the taxation of advertisements therefore restricts the right to an effective 
remedy and to a fair trial established in Article 47 of the Charter. 
The applicant notes that, under Article 52 of the Charter, any limitation on the 
exercise of the rights and freedoms recognised by the Charter must be provided 
for by law and respect the essence of those rights and freedoms. Subject to the 
principle of proportionality, limitations may be made only if they are necessary 
and genuinely meet objectives of general interest recognised by the Union or the 
need to protect the rights and freedoms of others. 
The defendant requests that the action brought in the administrative proceedings 
be dismissed. 
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In its opinion, it is not appropriate to talk of restrictions on grounds of nationality 
as regards the advertisement tax because the Law on the taxation of 
advertisements does not provide for a fine of one billion forint for breach of tax 
obligations to be imposed on foreign nationals alone: for domestic taxpayers, both 
Article 7/B and Article 7/C punish deliberate breach of tax obligations with a fine 
of the same amount, with a limit on the maximum cumulative amount.  
The defendant argues that, by deliberately ignoring its tax obligations, the 
applicant obtained a competitive advantage in Hungary over persons established 
in that country who publish advertisements and who comply with their tax 
obligations under the legislation. The fact that the applicant had been in breach of 
its obligations to pay the tax in Hungary since 1 January 2015 is such a serious 
breach that it is sufficient justification for applying a large fine, which encourages 
compliance with tax obligations and does not hinder freedom to provide services. 
Relevant EU law 
Article 18 TFEU stipulates that within the scope of application of the Treaties, and 
without prejudice to any special provisions contained therein, any discrimination 
on grounds of nationality is to be prohibited. 
Under Article 56 TFEU, restrictions on freedom to provide services within the 
Union are to be prohibited in respect of nationals of Member States who are 
established in a Member State other than that of the person for whom the services 
are intended. 
Article 41(1) of the Charter provides that every person has the right to have his 
affairs handled impartially, fairly and within a reasonable time by the institutions, 
bodies and agencies of the Union. 
Under Article 41(2) of the Charter this right includes, in particular: 
(a) the right of every person to be heard, before any individual measure which 
would affect him or her adversely is taken; 
(c) the obligation of the administration to give reasons for its decisions. 
Article 47 of the Charter, entitled ‘Right to an effective remedy and to a fair trial’, 
states that everyone whose rights and freedoms guaranteed by the law of the 
Union are violated has the right to an effective remedy before a tribunal in 
compliance with the conditions laid down in this Article. Everyone is entitled to a 
fair and public hearing within a reasonable time by an independent and impartial 
tribunal previously established by law. Everyone shall have the possibility of 
being advised, defended and represented. 
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Under Article 48(2) of the Charter, entitled ‘Presumption of innocence and right 
of defence’, respect for the rights of the defence of anyone who has been charged 
shall be guaranteed. 
Relevant Hungarian law 
The advertisement tax is a turnover-based consumption tax, and it was introduced 
into Hungarian law by the Law on the taxation of advertisements (which was 
enacted on 17 June 2014 and came into force in accordance with the provisions in 
Article 7(1) of Law XXXIV of 2014) with the legal objective of applying the 
principle of achieving a proportionate public burden sharing. 
Article [174](1) of Law LXXIV of 2014 amended Article 3(1) of the Law on the 
taxation of advertisements as regards the taxpayer, with effect from 1 January 
2015, by replacing the expression ‘taxpayer’ with ‘taxpayer irrespective of place 
of residence’. 
Article 2(1)(e) of the Law on the taxation of advertisements stipulates that the 
publication of paid advertisements on the internet is to be subject to the tax where 
the advertisements are mainly in Hungarian or mainly on internet pages that are in 
Hungarian. 
Article 2(2)(b) of the Law on the taxation of advertisements states that the 
commissioning of the publication of an advertisement is to be subject to the tax 
unless the customer who has commissioned the publication of the advertisement: 
(ba) has asked the taxpayer referred to in Article 3(1) to issue the declaration 
referred to in Article 3(3) and can provide reliable evidence that he has done so; 
and 
(bb) has not received the declaration requested under paragraph (ba) within 10 
working days of receipt of the invoice or accounting document concerning 
publication of the advertisement; and 
(bc) has submitted a declaration to the National Tax and Customs Authority 
regarding the situation referred to in paragraph (ba), the person who has published 
the advertisement and the payment for publication. 
Article 3(3) of the Law on the taxation of advertisements stipulates that a person 
who is a taxpayer within the meaning of Article 3(1) must state in the invoice, 
accounting document or other document concerning payment for the publication 
of the advertisement (in particular, in the contract for publication of an 
advertisement) either that it is required to pay the tax and will comply with its 
obligations to make a tax declaration and to pay the tax, or that in that tax year it 
is not required to pay the tax on publication of advertisements. 
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Article 7/B(1) of the Law on the taxation of advertisements states that a person 
who is a taxpayer within the meaning of Article 3(1) and who is not registered 
with the National Tax Authority as a taxpayer for the purposes of some form of 
tax must register by submitting the relevant form supplied by the National Tax 
Authority within 15 days of commencing an activity that is subject to the tax 
under Article 2(1). 
Article 7/B(2) provides that, where a taxpayer fails to comply with the obligation 
to register under Article 7/B(1), in addition to ordering it to comply, the National 
Tax Authority is to impose a fine of 10 million forint for failure to comply. 
Article 7/B(3) states that, in the case of repeated breaches of the obligation, the 
National Tax Authority is to impose a fine for failure to comply of three times the 
amount of the previous fine. 
Article 7/B(4) states that the National Tax Authority is to issue daily decisions 
confirming breach of the obligation to register under Article 7/B(1). These 
decisions are to be final and enforceable from the moment when notice of them is 
served, and they may be contested through administrative court proceedings. In 
those proceedings, only documentary evidence is to be admissible and the court 
must reach its decision without holding a hearing 
Article 7/D of the Law on the taxation of advertisements states that the total 
maximum amount of the fine for failure to comply that the National Tax Authority 
may impose on the same taxpayer under Articles 7/B and 7/C is one billion forint. 
In the case of companies whose registered office is in Hungary, Article 17(1)(b) of 
the Law on general tax procedures states that the taxpayer automatically satisfies 
the obligation to register with the National Tax and Customs Authority when it 
submits an application for registration (a completed form) plus attachments, 
together with an application for a tax identification number, to the court with 
jurisdiction with respect to the registry. Articles 7/B and 7/D of the Law on the 
taxation of advertisements therefore do not apply to companies whose registered 
office is in Hungary, but only to companies with a registered office abroad. 
Under Article 172 of the Law on general tax procedures, if a taxpayer fails to 
comply with the notification obligation (to register or to report any changes), the 
requirement to disclose data or to open a bank account, or the requirement to 
submit a tax declaration, it may be fined either 500 000 forint or 1 000 000 forint, 
depending on the circumstances. 
Article 172(7) of the Law on general tax procedures stipulates that where a 
penalty is imposed for non-compliance with the obligation to register, notify, 
report changes, submit a tax declaration, disclose data or open a bank account, or 
where Article 172(1)(f) applies, the Tax Authority shall ― and in the case of 
non-compliance with the obligation to issue receipts, may ― simultaneously order 
the taxpayer to comply by a prescribed deadline. If the taxpayer fails to meet the 
deadline laid down in the earlier decision, except in the case of the fine for failure 
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to comply under Article 172(1)(f), the fine imposed is to be doubled and a new 
payment deadline prescribed. In the event of compliance with the original 
deadline, the fine imposed pursuant to the previous sentence of this paragraph 
may be reduced without limitation. If the taxpayer is in the process of voluntary or 
involuntary insolvency proceedings or liquidation and is no longer able to comply 
at the time when the fine for failure to comply is imposed, the tax authority is not 
to issue the [abovementioned order]. 
Reasons why the request for a preliminary ruling is necessary 
The Court of Justice has on several occasions held that national legislation that 
enables a Member State, without good reason, to treat citizens and companies of 
other Member States less favourably in law than its own citizens and companies is 
unlawful. This particular prohibition on discrimination also covers indirect 
discrimination, which occurs where the unequal treatment is not based directly 
and openly on nationality or on the registered office of the companies in question, 
but where in practice the legislation specifically places foreign nationals at a 
disadvantage. Indirect discrimination is admissible only where there are 
imperative general interest reasons that make the chosen legislative provision 
suitable to achieve the desired objective and it does not go beyond what is 
necessary in order to attain that objective. 
The Court of Justice has also ruled that while the regulation of indirect taxes is a 
matter for Member States, they must exercise that power in accordance with EU 
law, and also that administrative measures and sanctions must not go beyond what 
is strictly necessary for the objective pursued, and a penalty must not be so 
disproportionate to the gravity of the infringement that it becomes an obstacle to 
the freedoms guaranteed by the Treaty. 
The explanatory memorandum regarding Article 7/B of the Law on the taxation of 
advertisements contains the following statement. 
Law XXII of 2014 on the taxation of advertisements includes generally within its 
scope the publication of advertisements on the various different platforms, having 
regard to the fact that a requirement to pay tax irrespective of the platform used 
satisfies the requirement for competitive neutrality. The critical area of the 
legislation is the requirement that advertisements published on the internet are 
subject to the tax because, in such cases, while the taxable event is indisputable 
and clear, the taxpayer who publishes the advertisement can easily avoid its tax 
obligations, especially if it does not have an establishment in Hungary. By making 
the customer who commissions publication liable for the tax and by making 
provision for the customer to submit a declaration regarding the publisher to the 
tax authority, the current legislation seeks to impose the requirement to comply 
with tax obligations (the obligation to register, to issue notices, to submit tax 
declarations and to pay the tax) individually on each publisher. However, 
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experience shows that other measures are needed in order to force publishers to 
comply with their tax obligations on a regular basis. 
The referring court concluded that it is doubtful whether Article 7/B of the Law on 
the taxation of advertisements is compatible with EU law, and these doubts were 
strengthened by Commission Decision C(2016) 6929 of 4 November 2016, which 
held that the Law on the taxation of advertisements is in breach of various aspects 
of EU law on State aid. In response to the Decision, on 16 May 2017 the 
[Hungarian] Parliament approved draft law No T/14684 to amend the Law on the 
taxation of advertisements, thereby indirectly acknowledging that the present law 
is illegal. In the opinion of this court, quite apart from the fact that the amendment 
has not affected the obligation to register, which is the point at issue in these 
proceedings, but rather deals with the requirement to pay the advertisement tax, an 
illegal tax that has been abolished with retrospective effect cannot provide the 
basis for an obligation to register with the Tax Authority. 
The Law on the taxation of advertisements governs the adoption of daily 
decisions, the amount of the fine, which reaches one billion forint within five 
days, and the fact that decisions have a single legal base, with the result that the 
fine for failure to comply is imposed on a daily basis and the sum is tripled before 
the taxpayer is aware of the earlier decision and therefore cannot rectify the 
omission before the imposition of the next fine. To put it another way, the 
provisions in the Law on the taxation of advertisements concerning the fine for 
failure to comply establish a severely repressive and punitive penalty regime and 
may be contrary to EU law in that, in the case of companies established abroad 
that fail to satisfy the obligation to register under Article 7/B(1) of the Law, 
Article 7/D of the Law provides for a fine for failure to comply of up to a 
maximum of one billion forint to be imposed for each breach, whereas for 
companies whose registered office is in Hungary, under Article 172(2) and (7) of 
the Law on general tax procedures, the maximum fine that may be imposed for 
breach of the requirements to notify, register, report changes and submit a tax 
declaration is significantly smaller (the fine for failure to comply is either 500 000 
forint or up to one million forint, depending on the circumstances). Moreover, 
companies with a registered office in Hungary that provide the same services as 
the applicant can satisfy their obligations under the Law on the taxation of 
advertisements far more easily, and the amounts they can be fined are 
disproportionately less. Given that the full amount of the fine for failure to comply 
can be imposed on the taxpayer within five days, through daily decisions, it is 
impossible for a foreign company to avoid the increase in the amount of the fine. 
The referring court takes the view that the case-law of the Court of Justice has 
provided no clear guidelines for national courts on the issues raised in the present 
case, where the obligation to register under Article 7/B(1) of the Law on the 
taxation of advertisements and the fine for failing to do so are seriously 
detrimental to companies incorporated in other Member States that are not 
established in Hungary, as in the case of the applicant, and may restrict freedom to 
provide services within the European Union. When establishing penalties, 
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Member States must respect the proportionality principle, and a fine which may 
be as much as 2 000 times higher can be compatible with the proportionality 
principle only if ― taking into account the seriousness of the breach ― it is 
necessary from a perspective of enforcement and prevention; it is doubtful 
whether the provisions in Article 7/B of the Law on the taxation of advertisements 
satisfy those criteria. 
In the opinion of the referring court, there may also be a breach of the right to 
good administration in Article 41(1) of the Charter, given that the fine for failure 
to comply is imposed on a daily basis and the amount is tripled before a service 
provider established abroad has even become aware of the earlier decision, 
meaning that it cannot rectify the omission before the next fine is imposed, and 
the fine will therefore inevitably reach the maximum amount of one billion forint. 
In the view of the administrative and labour court hearing this case, the question 
of a possible breach of Article 41(1) and Article 41(2)(a) of the Charter must also 
be considered if the decision cannot be contested in an administrative procedure 
and may be challenged by legal action in administrative court proceedings in 
which only documentary evidence is admissible and the court may not hold a 
hearing. 
The referring court asks the Court of Justice for guidance on whether the national 
legislation described above is compatible with Articles 18 and 56 TFEU and with 
[Article 41](1) and Article [41](2)(a) of the Charter. 
... [procedural elements of domestic law] 
Budapest, 13 July 2018. 
... [signatures]