OPTION
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Taxation of Employee - OPTION

Tax on spread at exercise.

Note that the tax base may be reduced if the employee is required to pay health care contributions (which is likely the case).

Tax on sale.

Sub Deduction - OPTION
May be possible, if reimbursement made. Written agreement advisable.
Withholding and Reporting - OPTION
Income Tax:
No.

Social Insurance Contributions:
Yes, employee-paid health tax likely due on award income, but employer is not required to withhold.
Securities Restrictions - OPTION

An electronic notification to the Hungarian securities regulator is required within 15 days after the shares are issued upon exercise (but it is possible to complete the notification at grant of the option).

No other securities law restrictions or obligations apply. Non-transferable stock options are not considered a public offering of securities for purposes of the EU Prospectus Regulation.

Exchange Controls - OPTION

None.

Plan Entitlement - OPTION

Generally, no, provided US (or non-Hungarian) law is the governing law.

Discrimination against part-time employees is generally prohibited.

The EU Council Directive 2000/78/EC prohibits age discrimination. Most, if not all, countries have adopted local rules implementing this Directive, which may have an impact on design of equity and other incentive plans in the EU, particularly on age or age and service provisions which give different treatment (e.g., accelerated or continued vesting) for those meeting the criteria.

Data Privacy - OPTION

A valid basis is required to collect, process and transfer personal data.

The EU Data Protection Regulation ("GDPR") became effective in all EU/EEA countries on 25 May 2018. It introduces new requirements and increases the powers of data protection authorities, rights of data subjects and potential penalties for non-compliance.

Accordingly, companies should review their approach to data privacy compliance in the context of equity plan administration and consider on which basis they may be able to rely to collect, process and transfer data.

Registration and notification requirements with local data privacy authorities may also apply.