Publication: Magyar Közlöny
Issue: MK-2010-181 (Year: 2010, Number: 181)
Era: contemporary
Section: 2010. évi CXXXIII. törvény
Paragraph Index: 1293

2. In the case of the territory referred to in subparagraph 3(b) of Article 2, double taxation shall be avoided as follows: (a) Where a resident of the territory referred to in subparagraph 3(b) of Article 2 derives income which, in accordance with the provisions of this Agreement may be taxed in the territory referred to in subparagraph 3(a) of Article 2, the territory referred to in subparagraph 3(b) of Article 2 shall, subject to the provisions of subparagraph (b) and subparagraph (c), exempt such income from tax. (b) Where a resident of the territory referred to in subparagraph 3(b) of Article 2 derives items of income which, in accordance with the provisions of Article 10, 11 or 12 may be taxed in the territory referred to in subparagraph 3(a) of Article 2, the territory referred to in subparagraph 3(b) of Article 2 shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in the territory referred to in subparagraph 3(a) of Article 2. Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is given which is attributable to such items of income derived from the territory referred to in subparagraph 3(a) of Article 2. (c) Where in accordance with any provision of the Agreement income derived by a resident of the territory referred to in subparagraph 3(b) of Article 2 is exempt from tax in that territory, such territory may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income. (d) The provisions of subparagraph (a) shall not apply to income derived by a resident of the territory referred to in subparagraph 3(b) of Article 2 where the other territory applies the provisions of this Agreement to exempt such income from tax or applies the provisions of paragraph 2 of Article 10, 11 or 12 to such income. Article 23 NON-DISCRIMINATION

Source: https://magyarkozlony.hu/hivatalos-lapok/4774126550d98855ec8bc2b0930e2d509c87cd18/dokumentumok/c4b3f5ffbe35f9a00c8df653ca85fec4299fad4e/letoltes