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Hungary: Related Information

Double Tax Treaties

Hungary has signed double-taxation treaties with the following countries:

  • Albania
  • Australia
  • Azerbeijan
  • Belgium
  • Brazil
  • Canada
  • Croatia
  • Czech Republic
  • Egypt
  • Finland
  • Germany
  • Hong Kong
  • India
  • Ireland
  • Italy
  • Kazakhstan
  • Latvia
  • Luxembourg
  • Malaysia
  • Mexico
  • Mongolia
  • Morocco
  • Norway
  • Philippines
  • Portugal
  • Russia
  • Serbia
  • Slovakia
  • South Africa
  • Sweden
  • Taiwan
  • Tunisia
  • Ukraine
  • Uruguay
  • Uzbekistan
  • Armenia
  • Austria
  • Belarus
  • Bosnia & Herzogovina
  • Bulgaria
  • China
  • Cyprus
  • Denmark
  • Estonia
  • France
  • Greece
  • Iceland
  • Indonesia
  • Israel
  • Japan
  • Kuwait
  • Lithuania
  • Macedonia
  • Malta
  • Moldova
  • Montenegro
  • Netherlands
  • Pakistan
  • Poland
  • Romania
  • San Marino
  • Singapore
  • Slovenia
  • Spain
  • Switzerland
  • Thailand
  • Turkey
  • UK
  • USA
  • Vietnam

Nearly all the treaties provide for a reduced withholding tax of 5% or 10% on dividends paid out to foreign shareholders, meaning a maximum rate of 8% in Hungary.

Double Tax Treaties concluded by Hungary do not include anti-avoidance clauses, and can often be used highly efficiently in international tax structures.

The table below gives the rates of withholding tax applied to dividend, interest and royalty payments between Hungary and its tax treaty partners. For dividends, the normal rate of withholding is given ('Reg. %') and also the lower rate that is applicable subject to a minimum level of shareholding ('Min. Hold.'), where applicable.

Country
Dividends
Interest
Royalties
Incoming
Outgoing
Reg. %
Lower rate
Reg. %
Lower rate
%
Min.
Hold.
%
Min. Hold.
%
%
Albania
10
5
25
10
5
25
0
5
Armenia
10
5
25
10
5
25
0/5/10(o)
5
Australia
15
15
15
15
10
10
Austria
10
10
10
10
0
0
Azerbaijan
8
8
8
8
8
8
Belarus
15
5
25
15
5
25
5
5
Belgium
10
10
10
10
15/0 (a)
0
Bosnia & Herzogovina
10
10
0
10
Brazil
15
15
15
15
10/15 (h)
25/15 (i)
Bulgaria
10
10
10
10
10
10
Canada
15
5/10 (n)
25
15
5
25
10/0 (b)
10/0 (c)
China
10
10
10
10
10
10
Croatia
10
5
25
10
5
25
0
0
Cyprus
0
0
15
5
25
10/0 (d)
0
Czech Rep.
15
5
25
15
5
25
0
10
Denmark
15
5
25
15
5
25
0
0
Egypt
15
20
25
15
20
25
15
15
Estonia
5
15
25
5
15
25
0/10(p)
5/10(q)
Finland
15
5
25
15
5
25
0
5/0 (b)
France
15
5
25
15
5
25
0
0
Greece
45
45
10
10
10
10/0 (b)
Germany
15
5
10
15
5
10
0
0
Hong Kong
5
10
10
5
10
10
0/5(p)
5
Iceland
5
10
25
5
10
25
0
10
India
10
10
10
10
10
10
Indonesia
15
15
15
15
15
15
Ireland
15
5
10
15
5
10
0
0
Israel
15
5
10
15
5
10
0
0
Italy
10
10
10
10
0
0
Japan
10
10
10
10
10/0 (d)
10/0 (b)
Kazakhstan
15
5
25
15
5
25
10
10
Korea (Republic of)
5
10
25
5
10
25
0
0
Kuwait
0
0
0
0
0
10
Latvia
5
10
25
5
10
25
0/10(p)
5/10(q)
Lithuania
5
10
25
5
10
25
0/10(p)
5/10(q)
Lux'mbourg
15
5
25
15
5
25
0
0
Macedonia
5
15
25
5
15
25
0
0
Malaysia
0
0
10
10
15/0 (f)
15
Malta
Maltese normal rate
15
5
25
10
10
Mexico
5
15
10
5
15
10
0/10(p)
10
Moldova
15
5
25
15
5
25
10
0
Mongolia
15
5
25
15
5
25
10
5
Montenegro
5
15
25
5
15
25
10
10
Morocco
12
12
12
12
10
10
Netherlands
15
5
25
15
5
25
0
0
Norway
10
10
10
10
0
0
Pakistan
20
15
25
20
15
25
15
15
Philippines
20
5
25
20
5
25
15
15
Poland
10
10
10
10
10
10
Portugal
15
10 (m)
25
15
10 (m)
25
10
10
Romania
15
5
40
15
5
40
15
10
Russia
10
10
10
10
0
0
San Marino
0/5
15
25
0/5
15
25
0
0
Serbia
5
15
25
5
15
25
10
10
Singapore
10
5
25
10
5
25
5
5
Slovakia
15
5
25
15
5
25
0
10
Slovenia
15
5
25
15
5
25
0/5(p)
5
South Africa
15
5
25
15
5
25
0
0
Spain
15
5
25
15
5
25
0
0
Sweden
15
5
25
15
5
25
0
0
Switzerland
10
10
10
10
10
0
Taiwan
10
10
10
10
Thailand
20
15
25
20
15
25
10/25 (e)
15
Tunisia
12
10
25
12
10
25
12
12
Turkey
15
10
25
15
10
25
10
10
Ukraine
15
5
25
15
5
25
10
5
UK
0/10/15(r)
0
10
15
0
10
0
0
Uruguay
15
15
15
15
15/0 (j)
15/10 (k)
Uzbekistan
10
10
10
10
USA
15
5
10
15
5
10
0
0
Vietnam
10
10
10
10
10
10

Notes:

  1. 0 % if the interest is paid for commercial credits, for credits between banks or for deposits at any bank;
  2. 0 % if the royalty is paid for works of literature, arts or science (cultural royalty);
  3. 0 % if the interest is paid by the state, by a province or by a local authority of the country of source;
  4. 0 % if the interest is paid for commercial credits or paid by the state, by a local authority, by the central bank or by another state-owned bank of the country of source;
  5. 10 % if the interest is paid to a bank;
  6. 0 % if the interest is paid for special credits determined by the laws of Malaysia;
  7. 20 % if the royalty is paid for "technical services";
  8. 10 % if the interest is paid for investment credits with a duration of at least 8 years;
  9. 25 % if the royalty is paid for brand name;
  10. 0 % if the interest is paid to the state, to a local authority, to the central bank or to another state-owned bank of the other country;
  11. 10 % if the royalty is paid for "technical services";
  12. 25 % respectively 20 % if the dividend is distributed to a silent partner;
  13. 10 % only in the case (additional criterion) if the share is held by the recipient for at least 2 years continuously before the dividend distribution;
  14. 10 % if the dividend is distributed by a Canadian "non-resident owned investment corporation" to a Hungarian company controlling at least 25 % of the votes in the Canadian corporation;
  15. 5% if the interest paid for a loan granted by a bank, 0% if the loan is guaranteed by the other state, the central bank or other special government institution;
  16. 0% applies to certain transactions of certain state-related entities;
  17. 5% applies to royalties for the usage of scientific and technical equipment;
  18. 15% applies if the beneficial owner receives dividends from income derived from tax exempt immovable property.

Latest Hungary Treaty Updates

Treaty Update: Oman - Hungary
10 November, 2016
Oman and Hungary signed a DTA on November 1, 2016.
Treaty Update: Hungary - Turkmenistan
20 June, 2016
Hungary and Turkmenistan signed a DTA on June 1.
Treaty Update: Turkmenistan - Hungary
10 June, 2016
Turkmenistan confirmed on July 7 that it had signed a DTA with Hungary.
Treaty Update: Iran - Hungary
26 June, 2015
According to preliminary media reports, Iran and Hungary completed a first round of DTA negotiations on June 17, 2015.
Treaty Update: Hungary - Luxembourg
25 March, 2015
Hungary and Luxembourg signed a DTA on March 10, 2015.
Treaty Update: Bahrain - Hungary
18 February, 2015
According to preliminary media reports, the Shura Council of Bahrain on February 15, 2015, approved a law that would ratify the DTA signed with Hungary.
Treaty Update: Jersey - Hungary
29 January, 2015
The TIEA between Jersey and Hungary will enter into force on February 13, 2015.
Treaty Update: Hungary - Uzbekistan
02 December, 2014
Hungary signed a protocol to amend its DTA with Uzbekistan on November 27, 2014.
Treaty Update: Hungary - United Arab Emirates
08 October, 2014
The DTA between Hungary and United Arab Emirates entered into force on October 4, 2014.
Treaty Update: Bahrain - Hungary
26 March, 2014
Bahrain's Cabinet on March 23, 2014, approved a law to ratify the DTA signed with Hungary.
Treaty Update: Saudi Arabia - Hungary
25 March, 2014
Saudi Arabia and Hungary signed a DTA on March 24, 2014.
Treaty Update: Hungary - Kosovo
10 March, 2014
According to preliminary media reports, the DTA signed between Hungary and Kosovo will enter into force on March 12, 2014.
Treaty Update: Bahrain - Hungary
26 February, 2014
Bahrain signed a DTA with Hungary on February 24, 2014.
Treaty Update: Hungary - Jersey
31 January, 2014
Hungary and Jersey signed a TIEA on January 28, 2014.
Treaty Update: Hungary - Various
23 October, 2013
Legislation to ratify the double tax agreements Hungary signed with the United Arab Emirates on April 30, 2013, and with Switzerland on September 12, 2013, was forwarded to Hungarian parliament for its approval on October 14, 2013.
Treaty Update: Hungary - Guernsey
23 October, 2013
A law to ratify the TIEA signed between Hungary and Guernsey on September 11, 2013, was forwarded to Hungary's parliament for its approval on October 14, 2013.
Treaty Update: Hungary - Various
18 October, 2013
According to preliminary media reports, Hungary on October 14, 2013, ratified the double tax agreements signed with Switzerland and the United Arab Emirates.
Treaty Update: Hungary - Kosovo
08 October, 2013
Hungary and Kosovo signed a DTA on October 3, 2013.
Treaty Update: Switzerland - Hungary
16 September, 2013
Switzerland and Hungary signed a new DTA on September 12, 2013, to replace their existing DTA dating back to 1981.
Treaty Update: Saudi Arabia - Hungary
12 June, 2013
Saudi Arabia's Cabinet on May 14, 2013, approved the signing of a draft DTA with Hungary,
Treaty Update: Hungary - United Arab Emirates
02 May, 2013
Hungary and the United Arab Emirates signed a DTA on April 30, 2013.
Treaty Update: Hungary - Cuba
05 March, 2013
Hungary has approved the commencement of negotiations towards the conclusion of a DTA with Cuba, according to a filing in the nation's Official Gazette on February 28, 2013.
Treaty Update: United Arab Emirates - Hungary
11 February, 2013
The United Arab Emirates Cabinet on February 4, 2013, approved a law that would ratify the DTA the nation signed with Hungary.
Treaty Update: Hungary - Various
03 January, 2013
According to preliminary media reports, Hungary's DTAs with Georgia and Qatar became effective on January 1, 2013.
Treaty Update: Hungary - Switzerland
03 December, 2012
According to preliminary media reports, Hungary's parliament approved a draft DTA Protocol with Switzerland on November 28, 2012.
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