Publication: Magyar Közlöny
Issue: MK-2011-75 (Year: 2011, Number: 75)
Era: contemporary
Section: 2011. évi LXXXIV. törvény
Paragraph Index: 555

e) Notwithstanding the provisions of sub-paragraph a) double taxation shall be avoided by allowing a tax credit as laid down in sub-paragraph b) aa) if in the Contracting States items of income or capital are placed under differing provisions of this Agreement or attributed to different persons (except pursuant to Article 9) and this conflict cannot be settled by a procedure in accordance with paragraph 3 of Article 24 and if as a result of this difference in placement or attribution the relevant income or capital would remain untaxed or be taxed lower than without this conflict or bb) if the competent authority of Germany notifies the competent authority of Hungary of other items of income to which it intends to apply the provisions of sub-paragraph b). Double Taxation is then avoided for the notified income by allowing a tax credit from the first day of the calendar year, next following that in which the notification was received and all legal requirements according to the internal law of Germany are fulfilled.

Source: https://magyarkozlony.hu/hivatalos-lapok/e28b93f48eeefbd42f7cf6bf52ec7292218bc1a0/dokumentumok/001a14bd593e7f41e8750ff8eb4adfad2b55c36b/letoltes