Publication: Magyar Közlöny
Issue: MK-2011-128 (Year: 2011, Number: 128)
Era: contemporary
Section: 2011. évi CXLIV. törvény
Paragraph Index: 824

(3) Where, by reason of a special relationship between the resident referred to in paragraph (1) and some other person, or between both of them and some third person, the amount of the income referred to in that paragraph exceeds the amount (if any) which would have been agreed upon between them in the absence of such a relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the income shall remain taxable according to the laws of each Contracting State, due regard being had to the other applicable provisions of this Convention.

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