Category: Hungary

The COVID-19 outbreak has become a new type of challenge for the entire world. The conditions of everyday life and day-to-day business operations have fundamentally changed as countries have gone under lockdown, economies have been shut almost entirely down and global supply chains torn to pieces.

Fortunately, the European Commission responded in time, and on March 12 stated, that the pandemic qualifies as an exceptional occurrence, as it is an extraordinary, unforeseeable event having a significant economic impact.

For this reason, the EC communicated a so-called “Temporary Framework” on March 19 that enables member states to introduce state aid measures under a new and, in many respects, looser regulation.

This framework allows a subsidy for the migration of business activities inside the EU, which was previously not permitted. Furthermore, the location of a project formerly had a significant role in determining whether such aid could be given, but not now. 

Taking the opportunity presented, the Hungarian government has also introduced a series of new subsidies for those who have been adversely affected by the epidemic but are ready to adapt and fight.

For those medium and large enterprises in the manufacturing and BSC sectors who are ready to take their business to the next level, a new, non-refundable subsidy scheme to improve competitiveness is available, with a maximum subsidy amount of EUR 800,000.

The competitiveness subsidy is available throughout Hungary, even in Budapest. Enter-prises should certify that that their sales revenue or the volume of their order has dropped by 25% as a result of the COVID-19 outbreak and there is causal link between the outbreak and the losses.

The costs of building, land purchase and purchase of assets and intangible assets are also eligible. The amount of aid received depends on the size of the investment; more than EUR 500,000, the aid intensity can be as high as 50%. This creates a good opportunity to take the next step by introducing industry 4.0 solutions to increase capability, for example.

An extended version of the competitiveness subsidy is expected to be launched in the end of June, with a raised threshold on the maximum subsidy amount, which will be calculated based on the quantified losses suffered due to the pandemic.

On top of cash grants, a number of favourable loan schemes have been introduced. A good example are the new investment and working capital loans, available at EXIMBANK with a maximum 2.5% interest rate and flexible repayment options.

In addition to that, there are four new and encouraging subsidized loan schemes available for SMEs as part of the Széchenyi Card Program. A job retention loan, with a maximum 0.1% interest rate, has a term of two years with a maximum amount of HUF 750 million to ensure salary coverage.

This could be combined with an overdraft loan, with a maximum 0.1% interest rate, for a term of two years with a maximum amount of HUF 100 mln. To ensure liquidity, a working capital loan, with a maximum 0.2% interest rate, has a term of three years and a maximum amount of HUF 250 mln. For those who have even greater plans, there is an in-vestment loan option up to a maximum of HUF 1 billion for a six-year term and with a maximum 0.5% interest rate.

Proper combination of the above options could be a significant tool to navigate through this stormy period.

Every company should be concerned by this crisis, but it affects each differently. The secret recipe still does not exist, and there is no general solution. An economic crisis inevitably carries risks and dangers, but with careful planning and with the help of appropriate advice, it may also present opportunities. Those who are able to seize these opportunities will coming out of the crisis more strongly.

By Marcell Tatai-Szabo, Senior Associate, Adam Gyorgy Bodor, Counsel, and Benjamin F. Marton, Junior Consultant, Noerr

“To be honest, I think the government handled the crisis as well as possible,” says Levente Csengery, Partner at KCG Partners. “The COVID-19 regulations do exactly what they’re supposed to – protect public health and keep us all alive, and they’re working.“ At the time of writing, Hungary has had 3535 confirmed cases (and 460 deaths) from the new coronavirus. 

Still, tackling the public health elements of the crisis is only part of the overall response. “The economic blowback has been significant and we’re all feeling it,“ Csengery says. “There have been layoffs left and right – both individual and collective dismissals.“ Csengery specializes in Employment law, and he is directly involved, he says, with “many such cases, so I’m pretty aware of them and the impact they have on people’s lives. However, I feel that there is light at the end of the tunnel and I think that this can be an opportunity for many businesses to transform their operating models to suit the new normal – this would, eventually, lead to an uptick in employment as well.“

As for new legislation designed to tackle the crisis, Csengery reports that “many of the laws are a bit unclear as to what they seek to achieve – which leads to us, as lawyers, being forced to interpret them in a restrictive, conservative, manner.“ He feels that this may prevent these legislative measures from achieving their full potential. “This was to be expected – the sole focus of our legislative bodies was the crisis and pumping out laws as quickly as possible to deal with it. What we’re in right now is a constant feedback loop to the government and they’re working tirelessly to improve these and concretize them so that businesses can have more predictability in their operations.“

Ultimately, Csengery says that he remains optimistic that the crisis can end by 2020. “Hungary’s numbers are looking good and we’re doing all we can to keep the curve flat,“ he says. “People are switching to remote working in many sectors of the economy and it should start improving in the coming months as well.“ He says that business models of many businesses “are undergoing transformation and fine-tuning, and I think that this can only benefit the economy.“

Just a few days after the entry into force of the special tax on retailers (effective as of 1 May 2020), which may amount to as much as 2.5% of their annual turnover, the Hungarian Government further tightened the rules on the distribution of food products by significantly restricting  traders’ freedom to negotiate purchase prices.

Government Decree no. 180/2020. (4 May), effective from 5 May 2020 until the end of the pandemic-related state of emergency, has added a restriction to the existing regulation provided by Act XCV of 2009 (i.e. Act on the Unfair Trading Practices in the Food Sector; “UTP Act”). According to the amendment, it will be considered an unfair trading practice if the trader vis-à-vis the food product’s supplier:

• unilaterally reduces the purchase price despite the supplier’s objections, or
• seeks contractual amendments aimed at price reduction by threatening the supplier with the cancellation of orders, the reduction of the quantity of orders, the cancellation of discounts or promotional activities, or by other means causing material or moral loss to the supplier.

When it came to negotiations with suppliers, traders’ constitutional right of contractual freedom was already limited by the former provisions of the UTP Act. Under those provisions, the traders cannot, either by mutual consent, legally agree with suppliers on the application of certain fees, services and contractual terms categorically prohibited by the UTP Act (e.g. logistical charge, listing fee, sharing of costs serving also the trader’s interests, payment deadlines exceeding the statutory time period, etc.).

The newly introduced rules further limit the bargaining power of traders for the protection of suppliers: in order to avoid suspicions of undue influence through threats, traders need to consider both their negotiation strategy and their approach in communicating with suppliers very carefully.

This might pose some difficulties in practice. During annual negotiations with the suppliers typical in the retail sector, traders negotiate not only the purchase prices, but all other contractual conditions applicable for the post-negotiation period (usually a year-long period) as well. Examples include joint marketing activities, promotional campaigns, category management and other merchant services concerning products that the supplier requests, and the progressive bonuses applied, etc. As a result, in the framework of the annual agreement, the parties actually agree on a complex “package of conditions”. Supplier prices form only one element but cannot be separated from the whole package, as additional elements are often designed with regard to the prices and the revenues; therefore, the prices and the other conditions interact with one another. This will likely be further affected by the newly introduced special retail tax on traders, which will certainly motivate traders to seek reductions in purchase prices.

It’s therefore imperative that, in the future, during annual negotiations traders pay particular attention to ensuring that their negotiation position and the bargaining strategy applied vis-à-vis suppliers (especially taking into consideration the unequal bargaining position of smaller suppliers), is not, either indirectly, perceived to force or threaten suppliers in order to procure agreement.

This is all the more important because the new rules place the burden of proof on traders in certain supplier-trader relations. A trader must prove that a reduction in the purchase price was not obtained in an unfair, threatening manner in case a National Food Chain Safety Office (NÉBIH) procedure is initiated following a supplier’s application. The burden of proof rests with the trader based on, on the one hand, its market power and thus on the extent of its bargaining power, and, on the other hand, on the bargaining power of the supplier.

The regulation assesses bargaining power based on annual turnover; accordingly, a trader is required to prove the lawfulness of the negotiations if:

• the turnover of the supplier does not exceed HUF 500 million, while the turnover of the trader exceeds HUF 1 billion;
• the supplier’s turnover exceeds HUF 500 million, but does not exceed HUF 5 billion, while the trader’s turnover exceeds HUF 20 billion;
• the turnover of the supplier exceeds HUF 5 billion, but does not exceed HUF 75 billion, while the turnover of the trader exceeds HUF 100 billion; and
• the supplier’s turnover exceeds HUF 75 billion, while the turnover of the trader exceeds HUF 200 billion.

For the purposes of the calculation of the turnover, the turnover of all related undertakings must be counted together in the case of both traders and suppliers. In case of a joint procurement, however, the turnover of each of the traders within the joint purchasing alliance or the business association must be counted together as well as the turnover obtained by the traders that jointly concluded the commercial contract.

Finally, traders that come to the attention of NÉBIH due to the suspicion of threatening conduct will also be in a more difficult position because the UTP Act prohibits NÉBIH procedures being resolved by way of a commitment. This means traders have no way of resolving proceedings initiated against them by undertaking to subsequently modify their practices or offering compensation to their suppliers.

In light of the new rules, it will be advisable for traders to consider, taking into account the restrictions set out above, the balance between the prices and conditions they consider to be desirable or at least acceptable, ahead of commencing negotiations with suppliers, and to adapt their negotiation strategy accordingly.

By Peter Mezei, Associate, Baker McKenzie

The Hungarian Competition Authority (HCA) has imposed a record fine on Booking.com for committing unfair commercial practices by misleadingly advertising certain hotel rooms with “free cancellation”, as well as for pressure selling. The authority has also banned the company from applying these practices as of 2021.

This decision, although seemingly a surprise for most players, falls in line with the practice of imposing significantly higher fines in unfair commercial practices cases than in previous years, which has also been admitted by the HCA. In 2019 the fine imposed in consumer protection cases was higher than for cartels, and it is even more so in 2020 so far.

1. The infringements for which the fine was imposed 

Pursuant to the decision, Booking.com B.V. has committed the following three unfair commercial practices:

1.1 Misleadingly advertising certain hotel rooms with “free cancellation”

The HCA has objected to two conducts in this respect, namely

1. the same rooms which were advertised with “free cancellation” were also available at significantly cheaper prices (with the exception of the actual cancellation by the consumer);
2. “free cancellation” faced time and other limitations which became evident to the consumer only after choosing the accommodation.

The HCA stated that the flexibility, i.e. the ability to cancel a booking comes at an additional cost built into the price of the accommodation. The consumer does not have to pay for the room only if the consumer cancels the room. However, the consumer must pay a higher price if it does not cancel the booking and uses the room. In the HCA’s interpretation the “possibility of cancellation” is not free, it is in fact included in the cost of the room, only the actual cancellation is free of charge. The HCA believes that consumers were harmed if they did not cancel such accommodation.

This decision falls in line with the authority’s recent enforcement practice of being highly critical with the use of the expression “free”. For instance, in the telecom sector, Magyar Telekom was found guilty (and fined €2 million) by the HCA for having failed to inform consumers that if they chose to obtain a mobile device at a discounted price or for free with the subscription contract, the monthly subscription fee would be higher than absent the device. For similar infringements, the HCA charged Telenor approximately €5.45 million in December 2019 and Vodafone approximately €600,000 in 2017.

The HCA has also fined Facebook in December 2019 for HUF 1.2 billion (3.6 million euros) for claims of the use of its services being free (e.g. “Free and anyone can join”), whereas the HCA stated consumers in fact paid for the use of Facebook by their detailed data, such as consumer preferences, interests and habits.  

1.2 Pressure selling

Using an aggressive, phycological pressure to achieve a fast booking by consumers (pressure selling); e.g. (“Highly sought after! (…), “Another booking! (…), “Last booking at the accommodation: Just now!”) (“Only 1 room left!”, “There are only 2 left!”).

The HCA highlighted that these messages appeared during all parts of the booking process, i.e. after the searches in the results list, then later on the sub-sites of each hotel, were highlighted by red, and later also during the further steps of the booking process, even during the last step of the consumer submitting its data (e.g. “someone in that accommodation is booking now“).

In the HCA’s view, taken together, all messages were intended to ensure that the consumer should not only take a decision about starting a booking, but also to end (complete) the booking.

Booking.com claimed that the messages which have appeared contain real-time information and the real content, i.e. they were valid. However, the HCA objected to this indicating an example that when a message with “new booking” appears on the screen, the consumer cannot know to what period and which room this message applies. Moreover, the HCA did not investigate the validity, but the aggressiveness of the communication.

1.3 Breach of duty of professional diligence

The HCA established that Booking.com has breached its duty of professional diligence by the non-unified appearance of “You can pay by Szép Card”. The HCA objected to the fact that the possibility to pay by “Szép” card was not indicated the same way over the entire booking platform, e.g. for some hotels it already appeared in the search hit list, while for others only if and when the consumer opened the sub-page of the given hotel and only in the “small print” section. Booking.com had changed this last practice prior to the decision, and this was taken into consideration when setting the fine.

2. Termination of the practices

The authority has banned the company from applying the above practices. In this context the HCA has obliged Booking.com to evidence to the HCA that

• it does not apply the statement “free cancellation” any longer if the consumer must pay a higher price for the same room than without the free cancellation option or when free cancellation has limits (or in these cases the limitations of free cancellation must be clearly indicated);
• it has discontinued applying messages aiming to pose a phycological pressure on consumers during the entire booking process in all its commercial practices; it may only apply such messages for the given accommodation and for the specific dates chosen by the consumer and only by indicating the real information (available accommodation and the number of the available rooms) and only regardless of the consumer opinions, and without indicating an additional value.

Booking.com had offered commitments in the proceeding, which were rejected by the authority.

The fine was also imposed irrespective of Booking.com’s undertakings offered in December 2019 to change its commercial behaviour in the context of the European Consumer Protection Cooperation (CPC). The HCA has pointed out that the commitments offered in the CPC proceedings were different to what would have been required here (e.g. in the CPC commitment Booking.com has offered to show valid statements, whereas in the Hungarian proceeding the HCA did not object to the validity of the statements but the statements as a whole amounting to pressure selling. The HCA has also argued that it had contacted the other CPC authorities and they agreed that it was not necessary to apply a coordinated investigation under the CPC Regulation as the different proceedings concerned different conducts based on different legal basis and different time periods.

3. What is to come in the future?

This trend of record fines for unfair commercial practices is expected to continue in the future.

This is not be limited to the travel sector – although the travel industry has been under close focus in recent years: after a sectoral inquiry finished in 2016 into the hotel online booking market, as well as the recent market analysis on the operation of digital comparison tools, among others, the functioning of online hotel comparison sites. The HCA has also revealed in the Booking.com decision that a proceeding is already ongoing against szallass.hu, the biggest Hungarian-owned travel booking site.

Naturally, the use of the expression “free” is not limited to the travel sector, and pressure selling is currently being investigated by the HCA in the e-commerce sector (alza.hu website).  

This also evidences a certain shift on the enforcement priorities of the Authority, with significantly more emphasis on unfair commercial practices matters than earlier. Certainly, it is easier to obtain information regarding alleged unfair commercial practices from the websites of undertakings, as opposed to the difficulty of uncovering secret cartels, but this is not the only reason – similar enforcement priorities  are also seen in other countries of the CPC network.

The shift is also visible with regards to the undertakings investigated. The HCA does not shy away from investigating and fining the largest companies, including Apple, Facebook and Viber, Booking.com, and in many cases being the first authority in fining these companies for a certain type of infringement.

The “biggest ever fine” charged by the HCA in Hungary for unfair consumer practices cases seem to change almost every month now, with the Booking.com fine unlikely to stay as such for very long. With commitments of investigated companies rejected in most cases, undertakings should pay even more attention to prior compliance to avoid investigation of the authorities.

By Anna Turi, Counsel, Schoenherr

On 4 May 2020 the European Data Protection Board (‘EDPB’) issued important Guidelines on the practice of websites using so-called “cookie walls”.

Under the regulations of GDPR, website providers are obliged to obtain the visitors’ consent to store a cookie on their device. A cookie is a small text file that is downloaded onto a ‘terminal equipment’ (e.g. a computer or smartphone) when the user accesses a website. It allows the website to recognise that user’s device and store some information about the user’s preferences or past actions. Experience has shown that many website providers put into place a script that will block content from being visible except for a request to accept cookies and the information about which cookies are being set and for what purposes data will be processed. In these cases, there is no possibility to access the content without clicking on the “Accept cookies” button. According to the Guideline, since the data subject is not presented with a genuine choice, its consent is not freely given.

EDPB also stated in its Guideline that those activities on a website, which are not especially related to giving a consent, such as simply scrolling down the page, cannot be considered as a given consent.

The importance of the above Guideline is not only to harmonize the different practices in the EU, but also to warn website providers that failing to comply with GDPR requirements may result in a fine.

By Adrienn Megyesi, Attorney at law, KCG Partners Law Firm

The coronavirus epidemic has shown that implementing appropriate occupational safety and health measures and providing adequate conditions are essential in all sectors regardless of the activity. After the coronavirus outbreak, the European Agency for Safety and Health at Work (EU-OSHA) had published a guidance for the workplace. Now, a couple of month later, at the end of April 2020, the EU-OSHA issued guidance on coming back to work. The goal of these non-binding guidelines is to help employers and workers to stay safe and healthy in a working environment that has been changed significantly by the COVID-19 pandemic.

The guidance covers six areas:

1. Risk assessment and appropriate measures, which includes:
2. Minimizing exposure to COVID-19 at work, assessing the risks, and putting control measures in place to first eliminate the risk and if that is not possible, to minimize worker exposure. Collective measures can be supplemented with individual measures such as protective equipment.
3. Resuming work after a period of closure, making a plan for when work resumes that takes account of health and safety, carrying out adaptations, training and new procedures.

• Coping with a high rate of absence, putting new methods and procedures in place and changing roles and responsibilities.

1. Managing workers working from home, minimizing the risks of workers who have not been able to prepare their home workplace properly. Adapting the home environment do avoid deficiency.
2. Involving workers, consulting workers and/or their representatives and the health and safety representatives about planned changes and how temporary processes will work in practice.
3. Taking care of workers who have been ill, special considerations required for those workers who have become seriously ill.
4. Planning and learning for the future, drawing up or updating the crisis contingency plans for shutdown and start-up events in the future.
5. Staying well informed, differentiating the reliable and accurate from the vague and misleading amongst the overwhelming amount of information related to COVID-19.
6. Information for sectors and occupations, a collection of sector specific guidelines related to COVID-19.

The guidance represents a crucial EU contribution in this important period, and will be updated regularly with reliable information as the situation evolves, to ensure that workers can return to a safe and healthy workplace environment.

By Levente Csengery, Partner, KCG Partners Law Firm

At the end of April 2020, the Hungarian Government submitted to the Parliament a bill on the termination of the undivided joint ownership on agricultural lands and the clarification of the data of the rightholders of properties deemed agricultural land in the land registry, aiming at the establishment of a clear and transparent land ownership structure.

The bill regulates the following three procedures in order to terminate the undivided joint ownership: (i) dividing the property between the owners, (ii) acquiring the property by one of the owners or (iii) in certain conditions, expropriation by the State. In the first case, any of the owners could initiate the termination of the undivided joint ownership by the notification of the land registry authority, and the initiating owner should also notify in writing all other owners and registered users of the land. The owners should agree on the properties to be created in the course of the division in a contract countersigned by an attorney at law, and an obligatory annex should be a draft map and an area sheet. In case of certain agricultural zones, the bill determines the minimum size for the properties to be created. If the total area of the property does not reach the minimum size determined by the bill, the first procedure mentioned may not be applicable, but the property may be acquired by one of the owners and any owner may initiate the seizure of the ownership ratios of the other owners. The approval of the agricultural administrative body would not be necessary for the acquisition of a land under the bill.

The other aim of the bill is the clarification of the data of the owners, since there are relatively high number of persons registered as owners in the land registry, the data of whom are incorrect. Therefore, the bill establishes the legal ground on the basis of which the land registry authorities may explore the unidentified persons being owners in the land registry for the clarification of the legal status of the affected properties.

By Lidia Suveges, Attorney at law, KCG Partners Law Firm

Balazs Sahin-Toth, Counsel in the Budapest office of Allen & Overy, working pro bono in conjunction with Peter Gardos from Hungary’s Gardos Mosonyi Tomori Law Firm and Hungarian solo practitioners Adel Kegye and Eleonora Hernadi, has persuaded the Hungarian Supreme Court to uphold the lower court’s decision that the Hungarian segregation of Roma students between 2003 and 2017 provided a lower level of education.

According to a summary provided by Allen & Overy, “despite numbering 600,000 to 800,000 people in Hungary, Roma people still face systemic discrimination and barriers of access to basic services, including medical care and education. Segregation in schools is a particular problem, with some parents and teachers actively seeking to separate Roma children from others, often resulting in the placement of Roma children in special educational needs schools or segregated classrooms.”

According to A&O, it and three other law firms “acted for 62 Roma children against a school, the municipality, and the state, arguing that their life chances had been negatively impacted by school segregation. The lawyers interviewed the children and their families and obtained permission to litigate. Having drafted the children’s submissions, they then advocated for the children in over 40 court hearings. Each child and each of their parents were able to testify.”

“This is the first time that there has been an attempt to quantify financially what illegal segregation is,” Allen & Overy reports. “The team originally claimed HUF 500,000 (approximately GBP 1,300) for every year a child spent in a segregated class. The smallest amount awarded in judgment was HUF 200,000 for half a year in a segregated class, and the most was HUF 3,500,000 for seven years in a segregated class. The damages fluctuated based on whether the child appeared to be hard-working and contributed to their own education. However, given the difficult and socially-challenging backgrounds from which the children came, the courts acknowledged that it was not always fair to make the children responsible for their own circumstances.”

The court of appeals increased the total amount of damages due to the Roma plaintiffs to approximately HUF 100 million (approximately GBP 266,000).

The Supreme Court upheld the appellate court’s judgment in full, in the process rejecting the defendant’s application that the Court order compensation to be provided in-kind (that is, in the form of additional education and training that they would organize and provide), rather than in money. According to Allen & Overy, “the Supreme Court held that moral damages (i.e., compensation for breaches of personality rights) may only be provided in money under the Civil Code as interpreted by jurisprudence and court cases from the past century. Interestingly, against the backdrop of political pressure from the Government, the Supreme Court pointed out in the judgment that it is bound by laws only and it cannot be instructed by the Government.”

According to Allen & Overy, “the Supreme Court with this judgment [did] its part in defending the rule of law.”

 

 

On 10 April 2020, the Government issued Decree No. 102/2020. (IV. 10) and introduced new temporary corporate law measures with the aim of facilitating the decision-making process of the companies in compliance with the restrictions on movement introduced due to the spread of the epidemic.

Pursuant to the new rules, all meetings of the decision-making bodies (e.g. members’ meeting or general meeting) and of other bodies of the company (e.g. board of directors, supervisory board) should not be held in a way which would require the personal presence of the members. If the members’ meeting might be held in compliance with the stay-at-home order, the new provisions are not applicable. This might be the case when the members of the company live in the same household. The decision making of the sole member companies are also not affected by the new provisions, they may make their resolutions in writing which takes effect upon its communication to the management.

In order to comply with the stay-at-home order, the members’ meeting (i) may be held by electronic means (i.e. videoconference/telephone conference) or (ii) the members may adopt a decision by a written resolution, even if the company’s articles of association does not provide for such option or it regulates the process otherwise. The decree also sets out certain requirements, such as identification requirements at the members’ meetings held by electronic means or procedural requirements for written voting procedures. If it is not possible to hold a members’ meeting in line with the above mentioned provisions, the management is entitled to decide on several subjects, for example to pass a decision on the approval of the annual financial report, on the payment of dividends, and also on matters which would fall within the members’ competency, provided that resolving such matter is urgent and necessary to maintain the lawful operation of the company.

Furthermore, if the mandate of the executive officer expires or he resigns during the state of emergency, he must remain in his position for 90 days after the end of the state of emergency and he is obliged to perform his related duties, unless a resolution of the members provides otherwise.

The term during which the new provisions are applicable has not yet been determined; their end date will be specified by a further decision of the Government or the Parliament.

By Rita Parkanyi, Partner, KCG Partners Law Firm

Subsequent to the previous reduction of the social contribution tax effective from 1 July 2019 (17.5%), which is the main labour-related tax burden of employers, the Hungarian legislation further decreases the social contribution tax as of 1 July 2020.

In line with the earlier plans, the new tax rate will be 15.5% defined by the modification. The new reduction affects also the tax burden of the cafeteria elements, which are subjects to social contribution tax. In case of this cafeteria elements the new tax rate is also applicable. One of the main long term goals of the Hungarian Government is to significantly improve the competitiveness of Hungary regarding the area of employment. The new modification is one of the steps of this goal but it was adopted under the special legislative procedure caused by COVID-19 situation.

The Hungarian Government plans to further decrease the tax burdens of employment (especially the social contribution tax) in the following years. The final proposed rate, which has been announced prior to the economic crisis caused by COVID-19, is 11.5% by 2022, provided that the economic environment allows it and other certain conditions are met.

By Gabriella Galik, Partner, KCG Partners Law Firm