Publication: Magyar Közlöny
Issue: MK-2011-75 (Year: 2011, Number: 75)
Era: contemporary
Section: 2011. évi LXXXIII. törvény
Paragraph Index: 158

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) 0 per cent of the gross amount of the dividends if the beneficialowner is a company (other than a partnershipthat is not liable to tax), which holds directly at least 10 per cent of the capital of the company paying the dividends where such holding is being owned for an uninterrupted period of no less than one year; (b) 0 per cent of the grossamount of the dividends if the beneficialowneris a pensionfund or other similarinstitution providing pension schemes in which individuals may participate in order to secure retirement benefits, where such pension fund or other similar institution is established and recognized for tax purposes in accordance with the laws of that other State; (c) 15 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/e28b93f48eeefbd42f7cf6bf52ec7292218bc1a0/dokumentumok/001a14bd593e7f41e8750ff8eb4adfad2b55c36b/letoltes