Publication: Magyar Közlöny
Issue: MK-2011-128 (Year: 2011, Number: 128)
Era: contemporary
Section: 2011. évi CXLIV. törvény
Paragraph Index: 791

(2) However, such dividends: (a) may alsobe taxed in the ContractingState of whichthe companypaying 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: (i) 10 per cent of the gross amount of the dividends, except as provided in sub-paragraph (a) (ii); (ii) 15 per cent of the gross amount of the dividends where those dividends are paid out of income (including gains) derived directly or indirectly from immovable property within the meaning of Article 6 by an investment vehicle which distributes most of this income annually and whose income from such immovable property is exempted from tax; (b) shall, notwithstanding the provisions of sub-paragraph (a), be exempt from tax in the Contracting State of which the company paying the dividends is a resident if the beneficial owner of the dividends is: (i) a company which is a resident of the other Contracting State and controls, directly or indirectly, at least 10 per cent of the voting powerin the companypaying the dividends (other than wherethe dividends are paid by an investment vehicle as mentioned in subparagraph (a) (ii)); or (ii) a pension scheme. Thisparagraphshallnotaffect thetaxationofthecompanyinrespectoftheprofitsout ofwhichthedividendsarepaid.

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