Publication: Magyar Közlöny
Issue: MK-2011-128 (Year: 2011, Number: 128)
Era: contemporary
Section: 2011. évi CXLV. törvény
Paragraph Index: 1084

2. However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 (five) per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership that is not liable to tax), which holds directly at least 10 (ten) per cent of the capital of the company paying the dividends; (b) 15 (fifteen) per cent of the gross amount of the dividends in all other cases. Thisparagraphshallnotaffect thetaxationofthecompanyinrespectoftheprofitsout ofwhichthedividendsarepaid. The competentauthoritiesofthe ContractingStatesshallby mutual agreementsettlethe modeofapplicationofthese limitations.

Source: https://magyarkozlony.hu/hivatalos-lapok/e5485bbe2b4799f35a054d9c427707c39671831b/dokumentumok/b22cbff19437bd824a6a45069abc926a3646e57f/letoltes