Publication: Magyar Közlöny
Issue: MK-2010-181 (Year: 2010, Number: 181)
Era: contemporary
Section: 2010. évi CXXXIII. törvény
Paragraph Index: 1272

6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each territory, due regard being had to the other provisions of this Agreement. Article 13 CAPITAL GAINS

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