The fact that my topic is evergreen is demonstrated by the fact that several authors have already written many pages to present, explore and draw up propositions to solve the problems and unlawfulness in the adoption of decrees by municipal councils. There have also been several other studies dealing with the means used by and available to government offices to eliminate the problems detected, and the solutions applied by them - but not specified by any law[1] - to warn the municipal council or competent body of the local government, the municipal clerk of the anomalies detected. The number of authors investigating how the Local Government Council of the Curia of Hungary reacts to the unlawfulness of the decrees during its procedure - as the last step of the legitimacy procedure initiated by the government office - is somewhat less.[2] Due to the foregoing, I present, in this paper, typical shortcomings - on a specific set of organisational and operational rules - which result from the infringement of and non-compliance with the requirements of Act CXXX of 2010 on Legislation (hereinafter referred to as Legislation Act) on the one hand and Decree No. 61/2009. (XII. 14.) IRM of the Minister of Justice and Law Enforcement on the Drafting of Legislation (hereinafter referred to as Legislation Drafting Decree) on the other hand. In my study, I also present the most important opinions of principle developed by the Local Government Council of the Curia of Hungary - which functions since 1 January 2012 - on practical examples which have been elaborated due to defects in tax decrees of local governments in the first place.
By virtue of Article 32(1)(a) of the Fundamental Law of Hungary, "In the management of local public affairs and within the framework of an Act, local governments shall adopt decrees." It further states in Paragraphs (2)-(3) that "Acting within their functions, local governments shall adopt local government decrees to regulate local social relations not regulated by an Act, and/or on the basis of authorisation by an Act." No local government decree shall conflict with any other legal regulation." By virtue of the quoted parts of the Fundamental Law, the local government has two main ways to make decrees: on the one hand, under specific statutory authorisation, on the other hand, if it is necessary for ensuring any local public matter not regulated by the law. Section 13 of Act CLXXXIX of 2011 on Hungary's Local Governments (hereinafter referred to as Local Governments Act) provides us with a list of the tasks local governments have to perform within the scope of local public affairs and locally available public functions. For the decrees adopted on the basis of the two cases indicated above, the fundamental requirements concerning legislation and legislative drafting are specified by the provisions of the Legislation Act and the Legislation Drafting Decree.
By virtue of Article 32(1)(h) of the Fundamental Law, decree-making by local governments also includes the right to levy local taxes, in other words: the local government decides - within the scope of managing local affairs and within the limits provided by the law - on the type and extent of local taxes. The legal framework is provided by Act C of 1990 on Local Taxes (hereinafter referred to as Local Taxes Act) in the first place, under which local governments are entitled to taxation on the grounds of the Local Taxes Act and in pursuance of the local decrees made within the framework thereof.[3] It must be highlighted that the
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local governments are entitled but are not obliged to levy local taxes. If they wish to take this opportunity, then the decrees they make accordingly may not run counter other laws,[4] special consideration should therefore be given to the determination of the rate of the local tax[5] and the definition[6] of the scope of benefits[7].
The review of local government decrees changed on 1 January 2012: while previously the Constitutional Court uniformly proceeded at the appropriate proposal in the event of any issue of constitutionality and legality, the new regulations grant it powers in case of local laws with issues of constitutionality only. By virtue of the Fundamental Law, Act CLXI of 2011 on the Organisation and Administration of Courts (hereinafter referred to as Court Organisation and Administration Act) and Act CLXXXIX of 2011 on Hungary's Local Governments (hereinafter referred to as Local Governments Act), it is the Curia of Hungary -most specifically: its Local Government Council -that decides on the conflict between the local government decrees and the laws and their annulment and the establishment of the local government's failing to fulfil its legislative obligation.
Another important change is that the scope of proposals that can be submitted to the Constitutional Court has become limited, on the one hand due to the changes in the subject matter indicated above, and on the other hand due to the changes in the scope of those who are entitled to submit proposals, in other words: in the even where a local government decree is in conflict with the Fundamental Law, the Government Office must contact the Government through the minister responsible for the lawfulness of local governments, and may, through this person, request the annulment of, either the entire or a part of, the decree in conflict with the Fundamental Law.[8]
Section 2(1) of the Legislation Act: "The law shall have a regulatory content which the person(s) to whom the law applies can unequivocally interpret." The Local Government Council of the Curia of Hungary interpreted this requirement in line with the principles previously developed by the Constitutional Court: "An actual or alleged inconsistency within a particular local government decree does not result in any breach of the law if the collision of the legal rules can be resolved with the interpretation of the law by the legal practitioner. The collision within the local government decree is however in breach of the law - it infringes the requirement of a clear, understandable and appropriately interpretable norm content in Section 2(1) of the Legislation Act - if the inconsistency cannot be resolved with the interpretation of the law, or if any of the inconsistent provisions is in conflict with any law of higher level at the same time."[9]
Section 2(3) of the Legislation Act "The date of entry into force of a law must be set in a way leaving time enough to prepare for the application of that law." The Local Government Council of the Curia of Hungary has investigated this statutory requirement in many cases during its procedures and has found that the norm set by the municipal council can meet the requirement in Section 2(3) of the Legislation Act only if the time necessary for adjusting one's behaviour to the norm - in a compliant way - is available to the person(s) to whom the law applies.[10] Determination of the required time period is and can be affected by several aspects, such as the aspects of economic policy or organisation, the Local Government Council may therefore adopt the decision that the local legislator has set the entry into force of the decree in a way that breaches the law in exceptional cases only."[11]
Section 3 of the Legislation Act: "No law may repeat any of the provisions of the Fundamental Law or any other law which the law at hand may not be in conflict with in pursuance of the Fundamental Law." The Local Government Council of the Curia of Hungary fine-tuned and interpreted the foregoing rule as follows, and it is formulated as an opinion in principle for legislation by local governments: "according to the right interpretation of Section 3 of the Legislation Act, this prohibition applies to the verbatim takeover of the content of a law of higher level, but may not apply to any case where the law in question concerns the content of a law of higher level in order to maintain the inner coherence of the law in question. Such a general prohibition of takeover - applicable to the content in general - would render the legislation of local
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governments impossible and result in a local legislation that runs counter the requirement of a generally interpretable norm content. It is repetition, in other words: verbatim takeover, that is prohibited by Section 3 of the Legislation Act."[12] "In addition to the unlawfulness of mechanic repetition, the internal coherence, the general interpretability of the norm may justify the repetition of text, which can therefore not result in the unlawfulness of the decree of the local government."[13]
In the following, I use a specific decree, the Organisational and Operational Rules adopted by the Municipal Council of the Municipality of Apátvarasd[14] to demonstrate the typical problems of legislative drafting, which are attributable to speedy and hasty lawmaking in the first place.
Point 2.3.4 of Schedule No 1 to the Legislative Drafting Decree precisely and clearly specifies the appropriate form for designating local government decrees. In this context, the first unit of the designation should be the precise name of the entity making the decree in question, the second unit should be the number and the date of promulgation of the decree and the term "önkormányzat rendelete" [Decree of the Municipal Council in English], the third unit should be the accurate title of the decree, applying the Hungarian "-ról", "-ről" suffix [which corresponds to the "on" preposition in English].
Apátvarasd Község Képviselő-testületének 3/2013. (IV. 30.) rendelet Apátvarasd Község Önkormányzat Szervezeti és Működési Szabályzatáról [in English: Decree No. 3/2013. (IV.30.) of the Municipal Council of the Municipality of Apátvarasd on the Organisational and Operational Rules of the Local Government of the Municipality Of Apátvarasd] - the designation of this decree is false, because the term "önkormányzat rendelete" [Decree of the Municipal Council] has been omitted.
By virtue of Section 51 of the Legislation Drafting Decree, the recitals are a logical unit of the law, without any normative content, and are applicable in draft legislation on the modification of the Fundamental Law and in new laws that are significant in social and political terms, and are also included in draft acts to be adopted within the legislative scope specified in the Fundamental Law. By virtue of the above rule, local government decrees do not contain any recitals but they do contain an introductory part under Section 52 of the Legislation Drafting Decree. The introduction should indicate the enabling provision(s) of the Fundamental Law or any other law (subject to the fact whether it is about original legislative powers or not), the legislative provision defining the functions and an expression referring to the legislative act.
The introductory part of the decree under investigation complies with the requirements of the Legislation Drafting Decree. "The Municipal Council of the Municipality of Apádvarasd, acting under the authorisation vested in it by Section 143(4)(a) of Act CLXXXIX of 2011 on Hungary's Local Governments and within its functions specified in Article 32(1)(d) of the Fundamental Law, orders the followings:".[15]
By virtue of Section 40(2) of the Legislative Drafting Decree, the serial number of chapters should be indicated with positive integers in the form of Roman numerals, and the first letter of the word "Chapter" and the title should be capitalised. By virtue of Section 44(4) of the Legislative Drafting Decree: "the numbering of paragraphs should restart in each section, and should be realised using positive integers in the form of Arabic numerals written between brackets within each section." Pursuant to Section 42 of the Legislative Drafting Decree, sections are numbered with positive integers in the form of Arabic numerals and the "§" sign. By virtue of Section 48(1) of the Legislation Drafting Decree "Points may be indicated with the lowercase letters of the Latin alphabet and with the ")" sign or with Arabic serials generated from positive integers."
"1. Name and seat of the local government, the municipal council and its bodies
Section 1(1) The official name of the Local Government: Local Government of the Municipality of Apátvarasd (hereinafter referred to as Local Government). Seat: 7720 Apátvarasd, Fő utca 56.
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(2) Official name of the Municipal Council: Apátvarasd Község Önkormányzat Képviselő-testülete [Municipal Council of the Local Government of the Municipality of Apátvarasd] (hereinafter referred to as Municipal Council).
(3) Name of the office of the Municipal Council: Pécsváradi Közös Önkormányzati Hivatal [Joint Local Government office of Pécsvárad] (hereinafter referred to as: Mayor's Office). Seat: 7720 Pécsvárad, Szentháromság tér 3.
(4) The Committee of the Municipal Council is the Committee of Social Affairs.
(5) Other bodies of the Municipal Council:
a. the Mayor of the Municipality of Apádvarasd,
b. the Municipal Clerk of the Pécsváradi Közös Önkormányzati Hivatal [Joint Local Government office of Pécsvárad].
2. Duties of local governments
Duties of the municipal local government are specified in Section 13(1) of Act CLXXIX of 2011 on Hungary's Local Governments (hereinafter referred to as Local Governments Act).
3. Rules for transferring powers
Section 3(1) The powers vested in the mayor by the Municipal Council are listed in Schedule 2 to the Organisational and Operational Rules.
(2) The powers vested in the Committee of Social Affairs by the Municipal Council are listed in Schedule 3 to the Organisational and Operational Rules.
(3) The holder of the powers transferred shall report on the decisions adopted by it to the Municipal Council on a quarterly basis.
(4) Powers that may not be transferred by the Municipal Council are specified by Act CLXXXIX of 2011 on Hungary's Local Governments (hereinafter referred to as Local Governments Act)."
"Section 22(1) Formulating the legislative text of draft decrees falls within the tasks of the Municipal Clerk.
Section 27(1) The standing committee of the Municipal Council is the Committee of Social Affairs and it consists of 3 municipal councillors.
Section 30(1) The Municipal Council may set up a temporary committee for certain temporary tasks, and specifies its duties, powers, members concurrently with its setting up."
The quoted part of the Organisational and Operational Rules demonstrate that it does not divide into chapters; as for the numbering of the sections, the first is followed by the third one and the notation is not uniform either - as one can see in case of Sections 22, 27 and 30 - and the marking of the points runs counter the requirements of the Legislation Drafting Decree.[16]
By virtue of Section 7 of the Legislation Act: (1) "The law must specify the date of its entry into force, which may be a day following the promulgation of that law. (2) If the aim of the regularisation may not otherwise be achieved, then the date of entry into force of the law may also be the date of promulgation; in this case, the time of entry into force shall be specified in hours and may not precede the time of promulgation."
As a general rule, the date of promulgation is included in the number of the decree; in many cases however, the date indicated there is not identical to the date given in the final provisions, and it also happens often that the date of entry into force is indicated in the number of the decree. Another typical mistake made by local legislators is setting the promulgation and entry into force to the same date, which is not a problem in itself, but they fail to provide the precise hour of the entry into force.
The issues raised in the foregoing are well illustrated by Decree No. 13/2015 (XII. 11.) of the Municipal Council of the Local Government of the Municipality of Sáp on the Organisational and Operational Rules of the Local Government[17] (which is false in itself due to the wrong spelling of the term "municipal council" [the Hungarian wording reads: "képviselő testület", but it should read with a hyphen: "képviselő-testület"] and the omission of the point after the year), according to the number and title of the decree, the date of promulgation was on 11 December 2015; one can however find the following wording in the final provisions: "I promulgated the Decree on 12 December 2015" - meaning that it is not identical with the date in the title, and, by virtue of the final provisions "This Decree enters into force on 12 December 2015.", meaning that the date of promulgation and the date of entry into force are the same, still, the local legislator did not provide for the precise time of entry into force.
Pursuant to Point 18.1 of Schedule No. 1 to the Legislative Drafting Decree: the number of the schedule with Arabic number, then the word "melléklet" [Schedule] and the precise number of the decree, finally, the short designation of the maker
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of the decree or the term "önkormányzati rendelethez" [to the Local Government Decree].
Within the meaning of the foregoing, the proper marking in the Organisational and Operational Rules examined would look as follows: Schedule No. 1 to Decree No. 3/2013. (IV. 30.) of the Local Government, however, one can see the following solution: Schedule No. 2 and Schedule No. 3 (the Decree has not got any Schedule No. 1).
The Local Taxes Act defines the concept of land[18], as the subject matter of tax liability, and lists the exceptions from this concept;[19] the land tax investigated on account of the specific case may apply to the subject of taxation under the law, the Municipal Council may not provide any alternative definition.[20] This is what the specific question is based on, as the modification of the Local Taxes Act resulted in the fact that the wording public cemetery, which previously has been among the exceptions, was not on the list between 1 January 2012 and 14 May 2012.[21]
Taking advantage of this "opportunity" many district governments[22] obliged Budapesti Temetkezési Intézet Zrt. [Budapest Funeral Institute Plc.] as taxpayer to pay land tax in their decrees. Therefore, the Local Government Council of the Curia of Hungary had to investigate if the imposition of the land taxes - which were of a different rate in each district - by the district governments concerned on the taxpayer has been lawful during this four and a half months. In order to answer this question, the Curia examined the so-called "local specificities", the relationship of the Metropolitan Government of Budapest and the district governments and the tax rate in the course of the procedures.
In its Section 6(c), the Local Taxes Act provides that the municipal council "shall set the tax rate in line with local specificities, the economic requirements of the local government and the ability to pay of taxable persons. "Local specificities" should not only be considered when establishing the tax rate, they might provide grounds for considering the imposition of taxes. Due to its previous cases, the Local Government Council regarded the dimensional specificities, functional differences[23] and location within the municipality of real estates in the outer belt areas of municipalities as "local specificities".[24] The question to investigate in this case is if the situation that there is a land subject to the public service function of public cemetery within the area of jurisdiction of the local government qualifies as a "local specificity". In this connection, we must touch upon the relationship between the Metropolitan Government of Budapest and the district governments as well: In Points 15 - 18 of its Decision No. Köf.5.022/2014/4.[25], the Local Government Council of the Curia of Hungary found that the division of duties and powers between the Metropolitan Government of Budapest and the district governments is basically different from the division of the same between municipal and county governments. This is the reason for the different legal status of the Metropolitan Government of Budapest and the district governments from that of other municipal governments, and this is due to the role the capital plays in the country and the fact that the entirety of the capital is a single settlement. Accordingly, Section 22(1) of the Local Governments Act specifies the two-level government system of the capital, and the fact that this results in equal fundamental municipal rights to the Metropolitan Government of Budapest and the district governments - their functions and powers may however be different. The establishment and maintenance of public cemeteries should be regarded as such difference, which lies with, pursuant to Section 23(4)(9) of the Local Governments Act, the General Assembly of the Capital.[26] The Local Government Council wanted to use this as a reference to the fact that - in the background of these cases - it is also problematic that the maintenance of public cemeteries, as a task concerning the entirety of the capital, rests with the Metropolitan Government of Budapest, while the right to levy land taxes is with the district governments. The aforementioned provisions of the Local Government Act allow for the conclusion that the entire settlement is interested in the arrangement of this public service, therefore it is an obligation that concerns the residents of the districts concerned as well. As a result of this, the individual districts are - in respect of organising and providing the public service - involved in terms of the obligation, but are also right holders in terms of the residential community.[27]
The Local Government Council touched upon the issue raised on the grounds of Section 6(d) of the Local Taxes Act, meaning that the definition of the scope of tax exemption belongs to the autonomy of the local government concerned, and the persons concerned by the issue should have considered this specific purpose in case of that piece of land that functions as a public cemetery within their area of their jurisdiction. In addition, the local governments involved in the case applied the same tax rate irrespective of the fact that the individual pieces of land are of different size and function, moreover, this tax rate was high in absolute terms
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in four of the six district governments investigated, and this may be capable of establishing the confiscating nature of this tax.[28]
The Local Government Council found that the imposing of land tax by the district governments involved on the public cemeteries in their area of jurisdiction was unlawful, because the fact that there is a piece of land that is subject to the public service function of public cemetery is to be assessed as a "local specificity". Against this background, the Local Government Council declared that the provisions set out in the local tax decrees involved in the case were unlawful between 1 January 2011 and 14 May 2012 due to their breaching of Section 6(c) of the Local Taxes Act. ■
NOTES
* This paper has been made within the framework of the programmes initiated by the Hungarian Ministry of Justice to raise the standard of legal education.
[1] The government offices strive for developing a "good practice", meaning the implementation of legal supervision with the involvement of and cooperation with those concerned, which means, for instance, continuous liaising on the phone between the clerks in the government office and the local government.
[2] See: Péter Tilk: A Kúria Önkormányzati Tanácsa helyi jogalkotással kapcsolatos elvárásai. [The requirements of the Local Government Council of the Curia of Hungary regarding local legislation.] Kodifikátor Alapítvány [Kodifikátor Foundation], Pécs, 2014.
[3] In more detail: Péter Tilk - Bianka Havasi - Ildikó Kovács: A helyi adókat szabályozó önkormányzati rendeletek felhatalmazáshoz kötöttsége a Kúria esetjogában. [Subjection of local government decrees regulating local taxes to authorisation in the case law of the Curia of Hungary.] Jogtudományi Közlöny [Journal of Legal Science] vol. 2015/2. p. 111.
[4] Compare with Article 32(3) of the Fundamental Law
[5] Compare with Section 6(c) of the Local Taxes Act
[6] Compare with Section 6(d) of the Local Taxes Act
[7] For the details of the requirements of the Curia in this subject area, see: Péter Tilk: quoted paper, pp. 58-64. For more details on the specific issue of taxation, see: Bianka Havasi: Telekadó tárgya a köztemető!? - a Kúria Önkormányzati Tanácsának gyakorlata. [Are public cemeteries subject to land tax?! - Practice of the Local Government Council of the Curia of Hungary.] Jegyző és Közigazgatás [Municipal Clerk and Public Administration], vol. May/June of 2015, pp. 29-30.
[8] See: Section 136(1) of the Local Governments Act.
[9] Decision No. Köf.5.017/2013/3.
[10] The issue of the availability of the required preparation time can therefore be raised by the decree on social services, in the case of which there were only two days between its promulgation and entry into force.
http://njt.hu/njtonkorm.php?njtcp=eh2eg7ed8dr3eo6dt1ee4em3cj4ca1cc2cd3by0cd1n See also:
http://njt.hu/njtonkorm.php?njtcp=eh4eg5ed4dr1eo4dt5ee0em9cj8bx3ce4bw9cc0cc3cb4h
[11] Decision No Köf. 5.038/2013/3.
[12] Decision No. Köf.5.056/2012/5.; Decision No. Köf.5.039/2013/4.; Decision No. Köf.5.057/2013/8.
[13] Decision No. Köf.5.057/2013/8.
[14] http://njt.hu/njtonkorm.php?njtcp=eh6eg3ed8dr9eo4dt9ee8em1cj8bx7cb4cd1by4ca3cc6g
[15] It often happens however, that the introduction makes references to the previous Constitution or the former Local Governments Act, such as in these cases:
http://njt.hu/njtonkorm.php?njtcp=eh8eg7ed6dr3eo2dt3ee8em9cj2cc5ce2bw1cf6by9m,
http://njt.hu/njtonkorm.php?njtcp=eh7eg2ed9dr2eo1dt6ee5em0cj3by4ca7ca6cf9cf2b,
http://njt.hu/njtonkorm.php?njtcp=eh4eg5ed2dr9eo8dt5ee2em5cj0bx1by2cb7by6bz1cd6b
One can also find examples where the local legislator uses recitals instead of an introduction, see:
http://njt.hu/njtonkorm.php?njtcp=eh6eg9ed4dr1eo0dt3ee8em7cj6cd3by2cb7cb8bz7j,
http://njt.hu/njtonkorm.php?njtcp=eh4eg5ed6dr7eo0dt5ee8em1cj6bx1bw8ce9ce8cd7by2h
[16] See also:
http://njt.hu/njtonkorm.php?njtcp=eh4eg1ed8dr1eo6dt5ee4em7cj8bx7cd6ce7by8bx1bz8d,
http://njt.hu/njtonkorm.php?njtcp=eh1eg6ed1dr6eo1dt4ee9em4cj9by2bw9cc4ca5bw4by7k,
http://njt.hu/njtonkorm.php?njtcp=eh9eg8ed3dr2eo9dt0ee5em8cj3bx6bz7bw8ce1cc2cb3e,
http://njt.hu/njtonkorm.php?njtcp=eh6eg1ed4dr9eo2dt7ee6em3cj2bx7cb8bx1cd2cb9by6c,
http://njt.hu/njtonkorm.php?njtcp=eh0eg3ed4dr7eo2dt1ee2em9cj2by1bw6ce9ca2cd3bx2d,
http://njt.hu/njtonkorm.php?njtcp=eh5eg8ed5dr2eo7dt0ee7em0cj5cd8by7ce8bz1cc6n,
http://njt.hu/njtonkorm.php?njtcp=eh3eg0ed5dr2eo3dt0ee9em6cj9cc8cf9cd4ca3bz6c,
http://njt.hu/njtonkorm.php?njtcp=eh4eg5ed0dr3eo2dt7ee4em9cj8cd9bz6ce7cc2cc5d,
http://njt.hu/njtonkorm.php?njtcp=eh7eg4ed9dr0eo1dt8ee5em6cj7cd8cc1bx2cb3bx8h,
http://njt.hu/njtonkorm.php?njtcp=eh4eg7ed0dr7eo6dt9ee4em5cj8bx9cb8by9ce0bw3bw8m
[17] http://njt.hu/njtonkorm.php?njtcp=eh1eg8ed5dr8eo7dt0ee1em6cj9bx6cc5bx2bx1by4cc1n
[18] Point 16 of Section 52 of the Local Taxes Act.
[19] Subpoints (a)-(i) of Point 16 of Section 52 of the Local Taxes Act.
[20] Decision No. 99/2011. (XI. 17.) AB of the Constitutional Court, DCC 2011, 776, 781.
[21] In more detail: Point II.4. of Decision No. Köf.5.051/2013.
[22] Specifically: 3[rd] District, Óbuda-Békásmegyer; 4[th] District, Újpest; 8[th] District, Józsefváros; 13[th] District, Hegyvidék; 15[th] District, Rákospalota, Pestújhely, Újpalota; 21[th] District, Csepel; 22[nd] District: Budafok-Tétény.
[23] Compare with Decision No. Köf.5.045/2013.
[24] Compare with Decision No. Köf.5.001/2013.
[25] In its later decisions, meaning Decisions No. Köf.5.033/2014.4., Köf.5.034/2014/5. Köf.5.060/2014/4., Köf.5.057/2014/4., Köf.5.064/2014/5. and Köf.5.061/2014/3, it provided the same finding, in line with the previous practice of the Constitutional Court, especially the findings made with a theoretical purpose in Decision No. 56/1996. (XII. 12.) of the Constitutional Court.
[26] This is supported by Section 8(3) of Act XLII of 1999 on Cemeteries and Burials.
[27] Previously, the Constitutional Court also dealt with this question in its Decision No. 821/B/2009. AB. This decree stated that - although the Budapesti Temetkezési Intézet Zrt. is not included in Point 35 of Section 52 of the Local Taxes Act, listing the organisations providing public service - the local government may grant tax exemption to other public service provid-
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ers, and the tax relief may be granted on the grounds of the function of the area in question.
[28] Compare with Decision No. Köf.5.081/2012/4.
Lábjegyzetek:
[1] The Author is doctoral student, Doctoral School of the Faculty of Law of the University of Pécs.
Visszaugrás
