Publication: Magyar Közlöny
Issue: MK-2010-32 (Year: 2010, Number: 32)
Era: contemporary
Section: szóló 1996. évi CXII. törvény 3. szakasz 1. bekezdésében felsorolt szolgáltatásokat, vagy bármely azt köve tõen
Paragraph Index: 927

1. With reference to paragraph 6 of Article 1 (General Scope) of the Convention, it is understood that income from sources within one of the Contracting States received by an entity that is organized in either of the Contracting States and that is treated as fiscally transparent under the laws of either Contracting State shall be treated as income derived by a resident of the other Contracting State to the extent that such income is subject to tax as the income of a resident of the other Contracting State. It is further understood that this paragraph shall not apply with respect to income received by an entity that is organized in a third state.

Source: https://magyarkozlony.hu/hivatalos-lapok/07d27bff30d27e1e27043370e8724dee864f7353/dokumentumok/8bfaa15ae64877eb1eb8cd5a9ff7a0cc8831b8d5/letoltes