l) Paragraphs 7 and 8 of Article 13 (Artificial Avoidance of Permanent Establishment Status through the Specific Activity Exemptions);
m) Paragraph 4 of Article 14 (Splitting-up of Contracts);
n) Paragraph 6 of Article 16 (Mutual Agreement Procedure);
o) Paragraph 4 of Article 17 (Corresponding Adjustments);
p) Article 18 (Choice to Apply Part VI);
q) Paragraph 4 of Article 23 (Type of Arbitration Process);
r) Paragraph 1 of Article 24 (Agreement on a Different Resolution);
s) Paragraph 1 of Article 26 (Compatibility); and
t) Paragraphs 1, 2, 3, 5 and 7 of Article 35 (Entry into Effect).
2. Notifications in respect of Covered Tax Agreements entered into by or on behalf of a jurisdiction or territory for whose international relations a Party is responsible, where that jurisdiction or territory is not a Party to the Convention pursuant to subparagraph b) or c) of paragraph 1 of Article 27 (Signature and Ratification, Acceptance or Approval), shall be made by the responsible Party and can be different from the notifications made by that Party for its own Covered Tax Agreements.
3. If notifications are made at the time of signature, they shall be confirmed upon deposit of the instrument of ratification, acceptance or approval, unless the document containing the notifications explicitly specifies that it is to be considered definitive, subject to the provisions of paragraphs 5 and 6 of this Article, and paragraph 7 of Article 35 (Entry into Effect).
4. If notifications are not made at the time of signature, a provisional list of expected notifications shall be provided at that time.
5. A Party may extend at any time the list of agreements notified under clause ii) of subparagraph a) of paragraph 1 of Article 2 (Interpretation of Terms) by means of a notification addressed to the Depositary. The Party shall specify in this notification whether the agreement falls within the scope of any of the reservations made by the Party which are listed in paragraph 8 of Article 28 (Reservations). The Party may also make a new reservation described in paragraph 8 of Article 28 (Reservations) if the additional agreement would be the first to fall within the scope of such a reservation. The Party shall also specify any additional notifications that may be required under subparagraphs b) through s) of paragraph 1 to reflect the inclusion of the additional agreements. In addition, if the extension results for the first time in the inclusion of a tax agreement entered into by or on behalf of a jurisdiction or territory for whose international relations a Party is responsible, the Party shall specify any reservations [pursuant to paragraph 4 of Article 28 (Reservations)] or notifications (pursuant to paragraph 2 of this Article) applicable to Covered Tax Agreements entered into by or on behalf of that jurisdiction or territory. On the date on which the added agreement(s) notified under clause ii) of subparagraph a) of paragraph 1 of Article 2 (Interpretation of Terms) become Covered Tax Agreements, the provisions of Article 35 (Entry into Effect) shall govern the date on which the modifications to the Covered Tax Agreement shall have effect.
6. A Party may make additional notifications pursuant to subparagraphs b) through s) of paragraph 1 by means of a notification addressed to the Depositary. These notifications shall take effect:
a) with respect to Covered Tax Agreements solely with States or jurisdictions that are Parties to the Convention when the additional notification is received by the Depositary:
i) for notifications in respect of provisions relating to taxes withheld at source, where the event giving rise to such taxes occurs on or after 1 January of the year next following the expiration of a period of six calendar months beginning on the date of the communication by the Depositary of the additional notification; and
ii) for notifications in respect of all other provisions, for taxes levied with respect to taxable periods beginning on or after 1 January of the year next following the expiration of a period of six calendar months beginning on the date of the communication by the Depositary of the additional notification; and
b) with respect to a Covered Tax Agreement for which one or more Contracting Jurisdictions becomes a Party to this Convention after the date of receipt by the Depositary of the additional notification: on the latest of the dates on which the Convention enters into force for those Contracting Jurisdictions.
The provisions in this Convention are without prejudice to subsequent modifications to a Covered Tax Agreement which may be agreed between the Contracting Jurisdictions of the Covered Tax Agreement.
1. The Parties may convene a Conference of the Parties for the purposes of taking any decisions or exercising any functions as may be required or appropriate under the provisions of this Convention.
2. The Conference of the Parties shall be served by the Depositary.
3. Any Party may request a Conference of the Parties by communicating a request to the Depositary. The Depositary shall inform all Parties of any request. Thereafter, the Depositary shall convene a Conference of the Parties, provided that the request is supported by one-third of the Parties within six calendar months of the communication by the Depositary of the request.
1. Any question arising as to the interpretation or implementation of provisions of a Covered Tax Agreement as they are modified by this Convention shall be determined in accordance with the provision(s) of the Covered Tax Agreement relating to the resolution by mutual agreement of questions of interpretation or application of the Covered Tax Agreement (as those provisions may be modified by this Convention).
2. Any question arising as to the interpretation or implementation of this Convention may be addressed by a Conference of the Parties convened in accordance with paragraph 3 of Article 31 (Conference of the Parties).
1. Any Party may propose an amendment to this Convention by submitting the proposed amendment to the Depositary.
2. A Conference of the Parties may be convened to consider the proposed amendment in accordance with paragraph 3 of Article 31 (Conference of the Parties).
1. This Convention shall enter into force on the first day of the month following the expiration of a period of three calendar months beginning on the date of deposit of the fifth instrument of ratification, acceptance or approval.
2. For each Signatory ratifying, accepting, or approving this Convention after the deposit of the fifth instrument of ratification, acceptance or approval, the Convention shall enter into force on the first day of the month following the expiration of a period of three calendar months beginning on the date of the deposit by such Signatory of its instrument of ratification, acceptance or approval.
1. The provisions of this Convention shall have effect in each Contracting Jurisdiction with respect to a Covered Tax Agreement:
a) with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the first day of the next calendar year that begins on or after the latest of the dates on which this Convention enters into force for each of the Contracting Jurisdictions to the Covered Tax Agreement; and
b) with respect to all other taxes levied by that Contracting Jurisdiction, for taxes levied with respect to taxable periods beginning on or after the expiration of a period of six calendar months (or a shorter period, if all Contracting Jurisdictions notify the Depositary that they intend to apply such shorter period) from the latest of the dates on which this Convention enters into force for each of the Contracting Jurisdictions to the Covered Tax Agreement.
2. Solely for the purpose of its own application of subparagraph a) of paragraph 1 and subparagraph a) of paragraph 5, a Party may choose to substitute „taxable period” for „calendar year”, and shall notify the Depositary accordingly.
3. Solely for the purpose of its own application of subparagraph b) of paragraph 1 and subparagraph b) of paragraph 5, a Party may choose to replace the reference to „taxable periods beginning on or after the expiration of a period” with a reference to „taxable periods beginning on or after 1 January of the next year beginning on or after the expiration of a period”, and shall notify the Depositary accordingly.
4. Notwithstanding the preceding provisions of this Article, Article 16 (Mutual Agreement Procedure) shall have effect with respect to a Covered Tax Agreement for a case presented to the competent authority of a Contracting Jurisdiction on or after the latest of the dates on which this Convention enters into force for each of the Contracting Jurisdictions to the Covered Tax Agreement, except for cases that were not eligible to be presented as of that date under the Covered Tax Agreement prior to its modification by the Convention, without regard to the taxable period to which the case relates.
5. For a new Covered Tax Agreement resulting from an extension pursuant to paragraph 5 of Article 29 (Notifications) of the list of agreements notified under clause ii) of subparagraph a) of paragraph 1 of Article 2 (Interpretation of Terms), the provisions of this Convention shall have effect in each Contracting Jurisdiction:
a) with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the first day of the next calendar year that begins on or after 30 days after the date of the communication by the Depositary of the notification of the extension of the list of agreements; and
b) with respect to all other taxes levied by that Contracting Jurisdiction, for taxes levied with respect to taxable periods beginning on or after the expiration of a period of nine calendar months (or a shorter period, if all Contracting Jurisdictions notify the Depositary that they intend to apply such shorter period) from the date of the communication by the Depositary of the notification of the extension of the list of agreements.
6. A Party may reserve the right for paragraph 4 not to apply with respect to its Covered Tax Agreements.
7.
a) A Party may reserve the right to replace:
i) the references in paragraphs 1 and 4 to „the latest of the dates on which this Convention enters into force for each of the Contracting Jurisdictions to the Covered Tax Agreement”; and
ii) the references in paragraph 5 to „the date of the communication by the Depositary of the notification of the extension of the list of agreements”; with references to „30 days after the date of receipt by the Depositary of the latest notification by each Contracting Jurisdiction making the reservation described in paragraph 7 of Article 35 (Entry into Effect) that it has completed its internal procedures for the entry into effect of the provisions of this Convention with respect to that specific Covered Tax Agreement”;
iii) the references in subparagraph a) of paragraph 9 of Article 28 (Reservations) to „on the date of the communication by the Depositary of the notification of withdrawal or replacement of the reservation”; and
iv) the reference in subparagraph b) of paragraph 9 of Article 28 (Reservations) to „on the latest of the dates on which the Convention enters into force for those Contracting Jurisdictions”; with references to „30 days after the date of receipt by the Depositary of the latest notification by each Contracting Jurisdiction making the reservation described in paragraph 7 of Article 35 (Entry into Effect) that it has completed its internal procedures for the entry into effect of the withdrawal or replacement of the reservation with respect to that specific Covered Tax Agreement”;
v) the references in subparagraph a) of paragraph 6 of Article 29 (Notifications) to „on the date of the communication by the Depositary of the additional notification”; and
vi) the reference in subparagraph b) of paragraph 6 of Article 29 (Notifications) to „on the latest of the dates on which the Convention enters into force for those Contracting Jurisdictions”; with references to „30 days after the date of receipt by the Depositary of the latest notification by each Contracting Jurisdiction making the reservation described in paragraph 7 of Article 35 (Entry into Effect) that it has completed its internal procedures for the entry into effect of the additional notification with respect to that specific Covered Tax Agreement”;
vii) the references in paragraphs 1 and 2 of Article 36 (Entry into Effect of Part VI) to „the later of the dates on which this Convention enters into force for each of the Contracting Jurisdictions to the Covered Tax Agreement”; with references to „30 days after the date of receipt by the Depositary of the latest notification by each Contracting Jurisdiction making the reservation described in paragraph 7 of Article 35 (Entry into Effect) that it has completed its internal procedures for the entry into effect of the provisions of this Convention with respect to that specific Covered Tax Agreement”; and
viii) the reference in paragraph 3 of Article 36 (Entry into Effect of Part VI) to „the date of the communication by the Depositary of the notification of the extension of the list of agreements”;
ix) the references in paragraph 4 of Article 36 (Entry into Effect of Part VI) to „the date of the communication by the Depositary of the notification of withdrawal of the reservation”, „the date of the communication by the Depositary of the notification of replacement of the reservation” and „the date of the communication by the Depositary of the notification of withdrawal of the objection to the reservation”; and
x) the reference in paragraph 5 of Article 36 (Entry into Effect of Part VI) to „the date of the communication by the Depositary of the additional notification”; with references to „30 days after the date of receipt by the Depositary of the latest notification by each Contracting Jurisdiction making the reservation described in paragraph 7 of Article 35 (Entry into Effect) that it has completed its internal procedures for the entry into effect of the provisions of Part VI (Arbitration) with respect to that specific Covered Tax Agreement”.
b) A Party making a reservation in accordance with subparagraph a) shall notify the confirmation of the completion of its internal procedures simultaneously to the Depositary and the other Contracting Jurisdiction(s).
c) If one or more Contracting Jurisdictions to a Covered Tax Agreement makes a reservation under this paragraph, the date of entry into effect of the provisions of the Convention, of the withdrawal or replacement of a reservation, of an additional notification with respect to that Covered Tax Agreement, or of Part VI (Arbitration) shall be governed by this paragraph for all Contracting Jurisdictions to the Covered Tax Agreement.
1. Notwithstanding paragraph 9 of Article 28 (Reservations), paragraph 6 of Article 29 (Notifications), and paragraphs 1 through 6 of Article 35 (Entry into Effect), with respect to two Contracting Jurisdictions to a Covered Tax Agreement, the provisions of Part VI (Arbitration) shall have effect:
a) with respect to cases presented to the competent authority of a Contracting Jurisdiction [as described in subparagraph a) of paragraph 1 of Article 19 (Mandatory Binding Arbitration)], on or after the later of the dates on which this Convention enters into force for each of the Contracting Jurisdictions to the Covered Tax Agreement; and
b) with respect to cases presented to the competent authority of a Contracting Jurisdiction prior to the later of the dates on which this Convention enters into force for each of the Contracting Jurisdictions to the Covered Tax Agreement, on the date when both Contracting Jurisdictions have notified the Depositary that they have reached mutual agreement pursuant to paragraph 10 of Article 19 (Mandatory Binding Arbitration), along with information regarding the date or dates on which such cases shall be considered to have been presented to the competent authority of a Contracting Jurisdiction [as described in subparagraph a) of paragraph 1 of Article 19 (Mandatory Binding Arbitration)] according to the terms of that mutual agreement.
2. A Party may reserve the right for Part VI (Arbitration) to apply to a case presented to the competent authority of a Contracting Jurisdiction prior to the later of the dates on which this Convention enters into force for each of the Contracting Jurisdictions to the Covered Tax Agreement only to the extent that the competent authorities of both Contracting Jurisdictions agree that it will apply to that specific case.
3. In the case of a new Covered Tax Agreement resulting from an extension pursuant to paragraph 5 of Article 29 (Notifications) of the list of agreements notified under clause ii) of subparagraph a) of paragraph 1 of Article 2 (Interpretation of Terms), the references in paragraphs 1 and 2 of this Article to „the later of the dates on which this Convention enters into force for each of the Contracting Jurisdictions to the Covered Tax Agreement” shall be replaced with references to „the date of the communication by the Depositary of the notification of the extension of the list of agreements”.
4. A withdrawal or replacement of a reservation made under paragraph 4 of Article 26 (Compatibility) pursuant to paragraph 9 of Article 28 (Reservations), or the withdrawal of an objection to a reservation made under paragraph 2 of Article 28 (Reservations) which results in the application of Part VI (Arbitration) between two Contracting Jurisdictions to a Covered Tax Agreement, shall have effect according to subparagraphs a) and b) of paragraph 1 of this Article, except that the references to „the later of the dates on which this Convention enters into force for each of the Contracting Jurisdictions to the Covered Tax Agreement” shall be replaced with references to „the date of the communication by the Depositary of the notification of withdrawal of the reservation”, „the date of the communication by the Depositary of the notification of replacement of the reservation” or „the date of the communication by the Depositary of the notification of withdrawal of the objection to the reservation”, respectively.
5. An additional notification made pursuant to subparagraph p) of paragraph 1 of Article 29 (Notifications) shall have effect according to subparagraphs a) and b) of paragraph 1, except that the references in paragraphs 1 and 2 of this Article to „the later of the dates on which this Convention enters into force for each of the Contracting Jurisdictions to the Covered Tax Agreement” shall be replaced with references to „the date of the communication by the Depositary of the additional notification”.
1. Any Party may, at any time, withdraw from this Convention by means of a notification addressed to the Depositary.
2. Withdrawal pursuant to paragraph 1 shall become effective on the date of receipt of the notification by the Depositary. In cases where this Convention has entered into force with respect to all Contracting Jurisdictions to a Covered Tax Agreement before the date on which a Party’s withdrawal becomes effective, that Covered Tax Agreement shall remain as modified by this Convention.
1. This Convention may be supplemented by one or more protocols.
2. In order to become a party to a protocol, a State or jurisdiction must also be a Party to this Convention.
3. A Party to this Convention is not bound by a protocol unless it becomes a party to the protocol in accordance with its provisions.
1. The Secretary-General of the Organisation for Economic Co-operation and Development shall be the Depositary of this Convention and any protocols pursuant to Article 38 (Relation with Protocols).
2. The Depositary shall notify the Parties and Signatories within one calendar month of:
a) any signature pursuant to Article 27 (Signature and Ratification, Acceptance or Approval);
b) the deposit of any instrument of ratification, acceptance or approval pursuant to Article 27 (Signature and Ratification, Acceptance or Approval);
c) any reservation or withdrawal or replacement of a reservation pursuant to Article 28 (Reservations);
d) any notification or additional notification pursuant to Article 29 (Notifications);
e) any proposed amendment to this Convention pursuant to Article 33 (Amendment);
f) any withdrawal from this Convention pursuant to Article 37 (Withdrawal); and g) any other communication related to this Convention.
3. The Depositary shall maintain publicly available lists of:
a) Covered Tax Agreements;
b) reservations made by the Parties; and c) notifications made by the Parties.
In witness whereof the undersigned, being duly authorised thereto, have signed this Convention.
Done at Paris, the 24th day of November 2016, in English and French, both texts being equally authentic, in a single copy which shall be deposited in the archives of the Organisation for Economic Co-operation and Development.
This document contains the list of reservations and notifications made by Hungary upon deposit of the instrument of ratification pursuant to Articles 28(5) and 29(1) of the Convention.
Notification - Agreements Covered by the Convention
Pursuant to Article 2(1)(a)(ii) of the Convention, Hungary wishes the following agreements to be covered by the Convention:
| No | Title | Other Contracting Jurisdiction | Original/ Amending Instrument | Date of Signature | Date of Entry intoForce | |
| 1 | Convention Between The Republic Of Hungary And The Republic Of Albania For The Avoidance Of Double Taxation With Respect To Taxes On Income And On Capital | Albania | Original | 14-11-1992 | 21-12-1995 | |
| 2 | Agreement Between The Government Of The Republic Of Hungary And The Government Of The Republic Of Armenia For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And On Capital | Armenia | Original | 09-11-2009 | 26-10-2010 | |
| 3 | Agreement Between The Republic Of Hungary And Australia For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | Australia | Original | 29-11-1990 | 10-04-1992 | |
| 4 | Convention Between The People’s Republic Of Hungary And The Republic Of Austria For The Avoidance Of Double Taxation With Respect To Taxes On Income And On Capital | Austria | Original | 25-02-1975 | 09-02-1976 | |
| 5 | Convention Between The Government Of The Republic Of Hungary And The Government Of The Republic Of Azerbaijan For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And On Capital | Azerbaijan | Original | 18-02-2008 | 15-12-2008 | |
| 6 | Convention Between The Government Of Hungary And The Government Of The Kingdom Of Bahrain For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | Bahrain | Original | 24-02-2014 | 19-06-2015 | |
| 7 | Convention Between The Republic Of Hungary And The Republic Of Belarus For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And On Capital | Belarus | Original | 19-02-2002 | 24-06-2004 | |
| 8 | Convention Between The Government Of The Hungarian People’s Republic And The Government Of The Kingdom Of Belgium For The Avoidance Of Double Taxation And Prevention Of Fiscal Evasion With Respect To Taxes On Income And Capital | Belgium | Original | 19-07-1982 | 25-02-1984 | |
| 9 | Convention between the Hungarian People’s Republic And the Socialist Federal Republic of Yugoslavia for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital | Bosnia andHerzegovina | Original | 17-10-1985 | 03-07-1987 | |
| 10 | Convention Between The Government Of The Hungarian People’s Republic And The Government Of The Federative Republic Of Brazil For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | Brazil | Original | 20-06-1986 | 13-07-1990 | |
| 11 | Convention Between The Republic Of Hungary And The Republic Of Bulgaria For The Avoidance Of Double Taxation With Respect To Taxes On Income And On Capital | Bulgaria | Original | 08-06-1994 | 07-09-1995 | |
| 12 | Convention Between The | Canada | Original | 15-04-1992 | 01-10-1994 | |
| Government Of The Republic Of Hungary And The Government Of Canada For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And On Capital | Amending Instrument (a) | 03-05-1994 | 26-04-1996 | |||
| 13 | Agreement Between The Government Of The Republic Of Hungary And The Government Of The People’s Republic Of China For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | China | Original | 17-06-1992 | 31-12-1994 | |
| 14 | Agreement Between The Republic Of Hungary And The Republic Of Croatia For The Avoidance Of Double Taxation With Respect To Taxes On Income And On Capital | Croatia | Original | 30-08-1996 | 07-06-1998 | |
| 15 | Convention Between The Republic Of Hungary And The Czech Republic For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And On Capital | CzechRepublic | Original | 14-01-1993 | 27-12-1994 | |
| 16 | Convention Between The Government Of The Hungarian People’s Republic And The Government Of The Republic Of Cyprus For The Avoidance Of Double Taxation With Respect To Taxes On Income And Capital | Cyprus | Original | 30-11-1981 | 24-11-1982 | |
| 17 | Convention Between The Republic Of Hungary And The Kingdom Of Denmark For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | Denmark | Original | 27-04-2011 | 19-07-2012 | |
| 18 | Convention Between The Government Of The Republic Of Hungary And The Government Of The Arab Republic Of Egypt For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | Egypt | Original | 05-11-1991 | 22-05-1994 | |
| 19 | Convention Between The Republic Of Hungary And The Republic Of Estonia For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And On Capital | Estonia | Original | 11-09-2002 | 05-07-2004 | |
| 20 | Convention Between The Hungarian People’s Republic And The Republic Of Finland For The Avoidance Of Double Taxation With Respect To Taxes On Income And On Capital | Finland | Original | 25-10-1978 | 24-07-1981 | |
| 21 | Convention Between The Government Of The Hungarian People’s Republic And The Government Of The French Republic For The Avoidance Of Double Taxation With Respect To Taxes On Income And On Capital | France | Original | 28-04-1980 | 01-12-1981 | |
| 22 | Agreement Between The Government Of Hungary And The Government Of Georgia For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And On Capital | Georgia | Original | 16-02-2012 | 13-05-2012 | |
| 23 | Agreement Between The Republic Of Hungary And The Federal Republic Of Germany For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And On Capital | Germany | Original | 28-02-2011 | 30-12-2011 | |
| 24 | Convention Between The Government Of The Hungarian People’s Republic And The Government Of The Hellenic Republic For The Avoidance Of Double Taxation With Respect To Taxes On Income And On Capital | Greece | Original | 25-05-1983 | 17-02-1985 | |
| 25 | Agreement Between The Government Of The Republic Of Hungary And The Government Of The Hong Kong Special Administrative Region Of The People’s Republic Of China For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | Hong Kong | Original | 12-05-2010 | 23-02-2011 | |
| 26 | Convention Between The Republic Of Hungary And The Republic Of Iceland For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | Iceland | Original | 23-11-2005 | 07-02-2006 | |
| 27 | Convention Between The Republic Of Hungary And The Republic Of India For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | India | Original | 03-11-2003 | 04-03-2005 | |
| 28 | Agreement Between The Government Of The Hungarian People’s Republic And The Government Of The Republic Of Indonesia For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | Indonesia | Original | 19-10-1989 | 15-02-1993 | |
| 29 | Convention Between The Republic Of Hungary And Ireland For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | Ireland | Original | 25-04-1995 | 05-12-1996 | |
| 30 | Convention Between The Government Of The Republic Of Hungary And The Government Of The State Of Israel For The Avoidance Of Double Taxation And For The Prevention Of Fiscal Evasion With Respect To Taxes On Income | Israel | Original | 14-05-1991 | 13-11-1992 | |
| 31 | Convention Between The Government Of The Hungarian People’s Republic And The Government Of The Italian Republic For The Avoidance Of Double Taxation With Respect To Taxes On Income And Capital And The Prevention Of Fiscal Evasion | Italy | Original | 16-05-1977 | 01-12-1980 | |
| 32 | Convention Between Japan And The Hungarian People’s Republic For The Avoidance Of Double Taxation With Respect To Taxes On Income | Japan | Original | 13-02-1980 | 25-10-1980 | |
| 33 | Convention Between The Republic Of Hungary And The Republic Of Kazakhstan For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And On Capital | Kazakhstan | Original | 07-12-1994 | 03-03-1996 | |
| 34 | Convention Between The Government Of The Hungarian People’s Republic And The Government Of The Republic Of Korea For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | Korea | Original | 29-03-1989 | 01-04-1990 | |
| 35 | Agreement Between The Republic | Kuwait | Original | 17-01-1994 | 21-12-1994 | |
| Of Hungary And The State Of Kuwait For The Avoidance Of Double Taxation With Respect To Taxes On Income And Capital And For The Fostering Of Economic Relations | Amending Instrument (a) | 09-12-2001 | 06-05-2003 | |||
| 36 | Convention Between The Republic Of Hungary And The Republic Of Latvia For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And On Capital | Latvia | Original | 14-05-2004 | 22-12-2004 | |
| 37 | Convention Between Hungary And The Principality Of Liechtenstein For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And On Capital | Liechtenstein | Original | 29-06-2015 | 24-12-2015 | |
| 38 | Convention Between The Republic Of Hungary And The Republic Of Lithuania For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And On Capital | Lithuania | Original | 12-05-2004 | 22-12-2004 | |
| 39 | Convention Between Hungary And The Grand Duchy Of Luxembourg For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And On Capital | Luxemburg | Original | 10-03-2015 | 26-01-2017 | |
| 40 | Agreement Between The Government Of The Hungarian People’s Republic And The Government Of Malaysia For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | Malaysia | Original | 22-05-1989 | 25-12-1992 | |
| 41 | Agreement Between The Republic Of Hungary And Malta For The Avoidance Of Double Taxation | Malta | Original | 06-08-1991 | 29-11-1992 | |
| 42 | Convention Between The Republic Of Hungary And The United Mexican States For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | Mexico | Original | 24-06-2011 | 31-12-2011 | |
| 43 | Convention Between The Government Of The Republic Of Hungary And The Government Of The Kingdom Of Morocco For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | Morocco | Original | 12-12-1991 | 20-08-2000 | |
| 44 | Convention Between The Government Of The Hungarian People’s Republic And The Government Of The Kingdom Of The Netherlands For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And On Capital | Netherlands | Original | 05-06-1986 | 25-09-1987 | |
| 45 | Convention Between The Hungarian Government And The Macedonian Government For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And On Capital | NorthMacedonia | Original | 13-04-2001 | 14-03-2002 | |
| 46 | Convention Between The Government Of The Hungarian People’s Republic And the Government Of The Kingdom Of Norway For The Avoidance Of Double Taxation With Respect To Taxes On Income And On Capital | Norway | Original | 21-10-1980 | 20-09-1981 | |
| 47 | Agreement Between The Government Of Hungary And The Government Of The Sultanate Of Oman For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | Oman | Original | 02-11-2016 | 18-03-2017 | |
| 48 | Convention Between The Republic | Pakistan | Original | 24-02-1992 | 06-02-1994 | |
| Of Hungary And The Islamic Republic Of Pakistan For The Avoidance Of Double Taxation With Respect To Taxes On Income | Amending Instrument (a) | 14-07-2020 | 19-11-2020 | |||
| 49 | Convention Between The Republic Of Hungary And The Republic Of The Philippines For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | Philippines | Original | 13-06-1997 | 07-02-1998 | |
| 50 | Convention Between The Republic | Poland | Original | 23-09-1992 | 10-09-1995 | |
| Of Hungary And The Republic Of Poland For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And On Capital | Amending Instrument (a) | 27-06-2000 | 01-05-2002 | |||
| 51 | Convention Between The Republic Of Hungary And The Portuguese Republic For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | Portugal | Original | 16-05-1995 | 22-02-1999 | |
| 52 | Agreement Between The Government Of Hungary And The Government Of The State Of Qatar For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | Qatar | Original | 18-01-2012 | 21-04-2012 | |
| 53 | Convention Between The Republic Of Hungary And Romania For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And On Capital | Romania | Original | 16-09-1993 | 14-12-1995 | |
| 54 | Convention Between The Republic Of Hungary And The Russian Federation For The Avoidance Of Double Taxation With Respect To Taxes On Income And On Capital | Russia | Original | 01-04-1994 | 03-11-1997 | |
| 55 | Convention Between The Republic Of Hungary And The Republic Of San Marino For The Avoidance Of Double Taxation With Respect To Taxes On Income | San Marino | Original | 15-09-2009 | 03-12-2010 | |
| 56 | Convention Between The Government Of Hungary And The Government Of The Kingdom Of Saudi Arabia For The Avoidance Of Double Taxation And The Prevention Of Tax Evasion With Respect To Taxes On Income And On Capital | Saudi Arabia | Original | 24-03-2014 | 01-05-2015 | |
| 57 | Convention Between The Republic Of Hungary And The Federal Republic Of Yugoslavia For The Avoidance Of Double Taxation With Respect To Taxes On Income And On Capital | Serbia | Original | 20-06-2001 | 13-12-2002 | |
| 58 | Agreement Between The Republic Of Hungary And The Republic Of Singapore For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | Singapore | Original | 17-04-1997 | 18-12-1998 | |
| 59 | Convention Between The Republic Of Hungary And The Slovak Republic For The Avoidance Of Double Taxation And the Prevention Of Fiscal Evasion With Respect To Taxes On Income And On Capital | SlovakRepublic | Original | 05-08-1994 | 21-12-1995 | |
| 60 | Convention Between The Republic Of Hungary And The Republic Of Slovenia For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And On Capital | Slovenia | Original | 26-08-2004 | 23-12-2005 | |
| 61 | Convention Between The Republic Of Hungary And The Republic Of South Africa For The Avoidance Of Double Taxation with Respect To Taxes On Income | South Africa | Original | 04-03-1994 | 05-05-1996 | |
| 62 | Convention Between The Government Of The Hungarian People’s Republic And The Government Of Spain For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And Capital | Spain | Original | 09-07-1984 | 20-05-1987 | |
| 63 | Convention Between The Government Of The Hungarian People’s Republic And The Government Of The Kingdom Of Sweden For The Avoidance Of Double Taxation With Respect To Taxes On Income And On Capital | Sweden | Original | 12-10-1981 | 15-08-1982 | |
| 64 | Convention Between Hungary And The Swiss Confederation For The Avoidance Of Double Taxation With Respect To Taxes On Income And On Capital | Switzerland | Original | 12-09-2013 | 09-11-2014 | |
| 65 | Convention Between The Government Of The Hungarian People’s Republic And The Government Of The Kingdom Of Thailand For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | Thailand | Original | 18-05-1989 | 10-12-1989 | |
| 66 | Convention Between The Republic Of Hungary And The Republic Of Tunisia For The Avoidance Of Double Taxation With Respect To Taxes On Income | Tunisia | Original | 22-10-1992 | 19-07-1997 | |
| 67 | Agreement Between The Republic Of Hungary And The Republic Of Turkey For The Avoidance Of Double Taxation With Respect To Taxes On Income | Turkey | Original | 10-03-1993 | 09-11-1995 | |
| 68 | Convention Between The Republic Of Hungary And Ukraine For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And On Property | Ukraine | Original | 19-05-1995 | 24-06-1996 | |
| 69 | Agreement Between The Government Of Hungary And The Government Of The United Arab Emirates For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | United Arab Emirates | Original | 30-04-2013 | 04-10-2014 | |
| 70 | Convention Between The Republic Of Hungary And The United Kingdom Of Great Britain And Northern Ireland For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And On Capital Gains | United Kingdom | Original | 07-09-2011 | 28-12-2011 | |
| 71 | Convention Between The Government Of The Hungarian People’s Republic And The Government Of The United States Of America For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | United States | Original | 12-02-1979 | 18-09-1979 | |
| 72 | Convention Between The Government Of The Republic Of Hungary And The Government Of The United States Of America For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | United States | Original | 04-02-2010 | N/A | |
| 73 | Convention Between The Government Of The Hungarian People’s Republic And The Government Of The Oriental Republic Of Uruguay For The Avoidance Of Double Taxation With Respect To Taxes On Income And On Capital | Uruguay | Original | 25-10-1988 | 13-08-1993 | |
| 74 | Agreement Between The Republic Of Hungary And The Socialist Republic Of Vietnam For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income | Vietnam | Original | 26-08-1994 | 30-06-1995 |
Reservation
Pursuant to Article 3(5)(a) of the Convention, Hungary reserves the right for the entirety of Article 3 not to apply to its Covered Tax Agreements.
Reservation
Pursuant to Article 4(3)(a) of the Convention, Hungary reserves the right for the entirety of Article 4 not to apply to its Covered Tax Agreements.
Reservation
Pursuant to Article 5(8) of the Convention, Hungary reserves the right for the entirety of Article 5 not to apply with respect to all of its Covered Tax Agreements.
Notification of Choice of Optional Provisions
Pursuant to Article 6(6) of the Convention, Hungary hereby chooses to apply Article 6(3).
Notification of Existing Preamble Language in Listed Agreements
Pursuant to Article 6(5) of the Convention, Hungary considers that the following agreements are not within the scope of a reservation under Article 6(4) and contain preamble language described in Article 6(2). The text of the relevant preambular paragraph is identified below.
| Listed Agreement Number | Other Contracting Jurisdiction | Preamble Text | |
| 1 | Albania | Desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income and on capital | |
| 2 | Armenia | <The Government of the Republic of Hungary and the Government of the Republic of Armenia,> desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, <and to further develop and facilitate their relationship,> | |
| 3 | Australia | DESIRING to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, | |
| 4 | Austria | attól az óhajtól vezetve, hogy a jövedelem-, a hozadéki és a vagyonadók területén elkerüljék a kettős adóztatást, von dem Wunsche geleitet, die Doppelbesteuerung auf dem Gebiete der Steuern vom Einkommen, Ertrag und vom Vermögen zu vermeiden, | |
| 5 | Azerbaijan | <The Government of the Republic of Hungary and the Government of the Republic of Azerbaijan,> desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, <and to further develop and facilitate their relationship,> | |
| 6 | Bahrain | <The Government of Hungary and the Government of the Kingdom of Bahrain,> desiring to conclude a Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, <and to further develop and facilitate their relationship,> | |
| 7 | Belarus | DESIRING to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, <and to further develop and facilitate their relationship,> | |
| 8 | Belgium | Désireux de conclure une convention tendant à éviter les doubles impositions et à prévenir l’évasion fiscale en matière d’impőts sur le revenu et sur la fortune et <de promouvoir et renforcer les relations économiques entre les deux pays>, | |
| 9 | Bosnia and Herzegovina | Desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income and on capital | |
| 10 | Brazil | Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income | |
| 11 | Bulgaria | Desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income and on capital, | |
| 12 | Canada | desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, | |
| 13 | China | Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income <for further development and promotion of their economic relationship> | |
| 14 | Croatia | desiring to conclude an Agreement for the avoidance of double taxation with respect to taxes on income and on capital | |
| 15 | Czech Republic | desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, | |
| 16 | Cyprus | Desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income and on capital; | |
| 17 | Denmark | desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, and to further develop and facilitate their relationship, | |
| 18 | Egypt | Desiring to conclude a Convention for the avoidance of the double taxation and the prevention of fiscal evasion with respect to taxes on income | |
| 19 | Estonia | Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, | |
| 20 | Finland | <Mindful of the principles set forth in the Final Act of the Conference on Security and Cooperation in Europe and> desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income and on capital, | |
| 21 | France | Désireux de conclure une Convention tendant à éviter les doubles impositions en matière d’impőts sur le revenu et sur la fortune | |
| 22 | Georgia | desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital | |
| 24 | Greece | desiring to avoid double taxation with respect to taxes on income and on capital; | |
| 25 | Hong Kong | Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income; | |
| 26 | Iceland | desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, | |
| 27 | India | desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income | |
| 28 | Indonesia | DESIRING to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, | |
| 29 | Ireland | Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, | |
| 30 | Israel | Desiring to conclude a Convention for the avoidance of double taxation and for the prevention of fiscal evasion with respect to taxes on income, | |
| 31 | Italy | <Désireux de développer et de faciliter les relations économiques mutuelles> ont décidé de conclure une Convention tendant à éviter les doubles impositions en matière d’impőts sur le revenu et sur la fortune et à prévenir les évasions fiscales | |
| 32 | Japan | Desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income, | |
| 33 | Kazakhstan | <Republic of Kazakhstan and Republic of Hungary desiring to enhance and develop economic, scientific, technical and cultural relations between both States and> desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, <have agreed as follows:> | |
| 34 | Korea | Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, <and to further develop and facilitate their economic relationship,> | |
| 36 | Latvia | Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, | |
| 37 | Liechtenstein | desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, and to further develop and facilitate their relationship without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance, | |
| 38 | Lithuania | Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, | |
| 39 | Luxemburg | Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, <and to further develop and facilitate their relationship> | |
| 40 | Malaysia | Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, <and to further develop and facilitate their economic relationship>, | |
| 41 | Malta | Desiring to conclude an Agreement for the Avoidance of Double Taxation and the prevention of fiscal evasion with respect to taxes on income, | |
| 42 | Mexico | desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and to further develop and facilitate their relationship, | |
| 43 | Morocco | - désireux d’éviter les doubles impositions en matière d’impőts sur le revenue, <- attachant une importance particulière à la promotion et au renforcement des relations économiques entre leurs pays> | |
| 44 | Netherlands | Desiring to replace by a new convention the Convention for the avoidance of double taxation with respect to direct taxes, | |
| 45 | North Macedonia | desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, and to further develop and facilitate their relationship, | |
| 46 | Norway | have decided to conclude a Convention for the avoidance of double taxation with respect to taxes on income and on capital, | |
| 47 | Oman | desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income <and to further develop and facilitate their economic relationships,> | |
| 48 | Pakistan | Desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income <and to further develop and facilitate their economic relationship> | |
| 49 | Philippines | Desiring to conclude a Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, | |
| 50 | Poland | Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital <and to further develop and facilitate their economic relationships>, | |
| 51 | Portugal | <The Portuguese Republic and the Republic of Hungary,> desiring to conclude a convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, <have agreed as follows:> | |
| 52 | Qatar | Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, <and to further develop and foster their relationship,> | |
| 53 | Romania | Desiring to promote and strengthen the economic relations between the two countries by concluding a Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital, | |
| 54 | Russia | Desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income and on capital, | |
| 55 | San Marino | wishing to conclude a Convention for the avoidance of double taxation with respect to taxes on income <and to strengthen the disciplined development of economic relations between the two States in the framework of greater cooperation> | |
| 56 | Saudi Arabia | Desiring to conclude a Convention for the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income and on capital, and to further develop and facilitate their relationship; | |
| 57 | Serbia | desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income and on capital, | |
| 58 | Singapore | Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, | |
| 59 | Slovak Republic | Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, | |
| 60 | Slovenia | desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, | |
| 61 | South Africa | desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income <and to further develop and facilitate their relationship,> | |
| 62 | Spain | Desiring to conclude a Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital | |
| 63 | Sweden | desiring to avoid double taxation with respect to taxes on income and on capital | |
| 64 | Switzerland | DESIRING to conclude a Convention for the avoidance of double taxation with respect to taxes on income and on capital | |
| 65 | Thailand | Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income <and to further develop and facilitate economic relationship> | |
| 66 | Tunisia | Désireux de conclure une convention en vue d’éviter les doubles impositions en matière d’impőt sur le revenu et de promouvoir et renforcer les relations économiques entre les deux pays. | |
| 67 | Turkey | Desiring to conclude an Agreement for the avoidance of double taxation with respect to taxes on income and to further develop and facilitate their economic relationship | |
| 68 | Ukraine | desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on property, <and confirming their endeavour to the development and their deepening of mutual relations,> | |
| 69 | United Arab Emirates | <Desiring to promote their mutual economic relations> through the conclusion between them of an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, | |
| 70 | United Kingdom | <The Republic of Hungary and the United Kingdom of Great Britain and Northern Ireland,> desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains, | |
| 71 | United States | <The Government of the Hungarian People’s Republic and the Government of the United States of America, desiring to further expand and facilitate mutual economic relations,> have resolved to conclude a convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, | |
| 72 | United States | <The Government of the Republic of Hungary and the Government of the United States of America,> desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, <have agreed as follows:> | |
| 73 | Uruguay | Desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income and on capital | |
| 74 | Vietnam | Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, |
Notification of Listed Agreements Not Containing Existing Preamble Language
Pursuant to Article 6(6) of the Convention, Hungary considers that the following agreements do not contain preamble language referring to a desire to develop an economic relationship or to enhance co-operation in tax matters.
| Listed Agreement Number | Other Contracting Jurisdiction | |
| 4 | Austria | |
| 9 | Bosnia and Herzegovina | |
| 12 | Canada | |
| 14 | Croatia | |
| 15 | Czech Republic | |
| 17 | Denmark | |
| 19 | Estonia | |
| 20 | Finland | |
| 24 | Greece | |
| 25 | Hong Kong | |
| 32 | Japan | |
| 36 | Latvia | |
| 37 | Liechtenstein | |
| 38 | Lithuania | |
| 41 | Malta | |
| 42 | Mexico | |
| 45 | North Macedonia | |
| 49 | Philippines | |
| 51 | Portugal | |
| 54 | Russia | |
| 56 | Saudi Arabia | |
| 57 | Serbia | |
| 58 | Singapore | |
| 59 | Slovak Republic | |
| 60 | Slovenia | |
| 63 | Sweden | |
| 64 | Switzerland | |
| 66 | Tunisia | |
| 67 | Turkey | |
| 70 | United Kingdom | |
| 72 | United States | |
| 74 | Vietnam |
Notification of Choice of Optional Provisions
Pursuant to Article 7(17)(b) of the Convention, Hungary hereby chooses to apply Article 7(4).
Notification of Existing Provisions in Listed Agreements
Pursuant to Article 7(17)(a) of the Convention, Hungary considers that the following agreements are not subject to a reservation under Article 7(15)(b) and contain a provision described in Article 7(2). The article and paragraph number of each such provision is identified below.
| Listed Agreement Number | Other Contracting Jurisdiction | Provision | |
| 6 | Bahrain | Article 27 | |
| 30 | Israel | Article 25 | |
| 33 | Kazakhstan | Article 11(8), Article 12(7) | |
| 37 | Liechtenstein | Article 28 | |
| 42 | Mexico | Article 22 (1) and (2) | |
| 47 | Oman | Article 28 | |
| 56 | Saudi Arabia | Article 28 | |
| 64 | Switzerland | Protocol 3 | |
| 68 | Ukraine | Article 11(7), Article 12(6) | |
| 70 | United Kingdom | Article 10 (6), Article 11 (5), Article 12 (5), Article 21 (4) |
Reservation
Pursuant to Article 8(3)(a) of the Convention, Hungary reserves the right for the entirety of Article 8 not to apply to its Covered Tax Agreements.
Reservation
Pursuant to Article 9(6)(a) of the Convention, Hungary reserves the right for Article 9(1) not to apply to its Covered Tax Agreements.
Reservation
Pursuant to Article 10(5)(a) of the Convention, Hungary reserves the right for the entirety of Article 10 not to apply to its Covered Tax Agreements.
Reservation
Pursuant to Article 11(3)(a) of the Convention, Hungary reserves the right for the entirety of Article 11 not to apply to its Covered Tax Agreements.
Reservation
Pursuant to Article 12(4) of the Convention, Hungary reserves the right for the entirety of Article 12 not to apply to its Covered Tax Agreements.
Reservation
Pursuant to Article 13(6)(a) of the Convention, Hungary reserves the right for the entirety of Article 13 not to apply to its Covered Tax Agreements.
Reservation
Pursuant to Article 14(3)(a) of the Convention, Hungary reserves the right for the entirety of Article 14 not to apply to its Covered Tax Agreements.
Reservation
Pursuant to Article 15(2) of the Convention, Hungary reserves the right for the entirety of Article 15 not to apply to the Covered Tax Agreement to which the reservations described in Article 12(4), Article 13(6)(a) or (c), and Article 14(3)(a) apply.
Reservation
Pursuant to Article 16(5)(a) of the Convention, Hungary reserves the right for the first sentence of Article 16(1) not to apply to its Covered Tax Agreements on the basis that it intends to meet the minimum standard for improving dispute resolution under the OECD/G20 BEPS Package by ensuring that under each of its Covered Tax Agreements (other than a Covered Tax Agreement that permits a person to present a case to the competent authority of either Contracting Jurisdiction), where a person considers that the actions of one or both of the Contracting Jurisdictions result or will result for that person in taxation not in accordance with the provisions of the Covered Tax Agreement, irrespective of the remedies provided by the domestic law of those Contracting Jurisdictions, that person may present the case to the competent authority of the Contracting Jurisdiction of which the person is a resident or, if the case presented by that person comes under a provision of a Covered Tax Agreement relating to non-discrimination based on nationality, to that of the Contracting Jurisdiction of which that person is a national; and the competent authority of that Contracting Jurisdiction will implement a bilateral notification or consultation process with the competent authority of the other Contracting Jurisdiction for cases in which the competent authority to which the mutual agreement procedure case was presented does not consider the taxpayer’s objection to be justified.
Notification of Existing Provisions in Listed Agreements
Pursuant to Article 16(6)(b)(i) of the Convention, Hungary considers that the following agreements contain a provision that provides that a case referred to in the first sentence of Article 16(1) must be presented within a specific time period that is shorter than three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Covered Tax Agreement. The article and paragraph number of each such provision is identified below.
| Listed Agreement Number | Other Contracting Jurisdiction | Provision | |
| 12 | Canada | Article 25(1), second sentence | |
| 28 | Indonesia | Article 25(1), second sentence | |
| 49 | Philippines | Article 24(1), second sentence | |
| 51 | Portugal | Article 25(1), second sentence |
Pursuant to Article 16(6)(b)(ii) of the Convention, Hungary considers that the following agreements contain a provision that provides that a case referred to in the first sentence of Article 16(1) must be presented within a specific time period that is at least three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Covered Tax Agreement. The article and paragraph number of each such provision is identified below.
| Listed Agreement Number | Other Contracting Jurisdiction | Provision | |
| 1 | Albania | Article 26(1), second sentence | |
| 2 | Armenia | Article 25(1), second sentence | |
| 3 | Australia | Article 25(1), second sentence | |
| 5 | Azerbaijan | Article 25(1), second sentence | |
| 6 | Bahrain | Article 24(1), second sentence | |
| 7 | Belarus | Article 26(1), second sentence | |
| 8 | Belgium | Article 25(1), second sentence | |
| 9 | Bosnia and Herzegovina | Article 25(1), second sentence | |
| 11 | Bulgaria | Article 26(1), second sentence | |
| 13 | China | Article 25(1), second sentence | |
| 14 | Croatia | Article 25(1), second sentence | |
| 15 | Czech Republic | Article 25(1), second sentence | |
| 16 | Cyprus | Article 26(1), second sentence | |
| 17 | Denmark | Article 23(1), second sentence | |
| 18 | Egypt | Article 25(1), second sentence | |
| 19 | Estonia | Article 25(1), second sentence | |
| 20 | Finland | Article 25(1), second sentence | |
| 21 | France | Article 26(1), second sentence | |
| 22 | Georgia | Article 26(1), second sentence | |
| 23 | Germany | Article 24(1), second sentence | |
| 24 | Greece | Article 26(1), second sentence | |
| 25 | Hong Kong | Article 23(1), second sentence | |
| 26 | Iceland | Article 24(1), second sentence | |
| 27 | India | Article 25(1), second sentence | |
| 29 | Ireland | Article 25(1), second sentence | |
| 30 | Israel | Article 26(1), second sentence | |
| 31 | Italy | Article 26(1), second sentence | |
| 32 | Japan | Article 25(1), second sentence | |
| 33 | Kazakhstan | Article 25(1), second sentence | |
| 34 | Korea | Article 25(1), second sentence | |
| 35 | Kuwait | Article 25(1), second sentence | |
| 36 | Latvia | Article 25(1), second sentence | |
| 37 | Liechtenstein | Article 25(1), second sentence | |
| 38 | Lithuania | Article 25(1), second sentence | |
| 39 | Luxemburg | Article 25(1), second sentence | |
| 40 | Malaysia | Article 25(1), second sentence | |
| 41 | Malta | Article 25(1), second sentence | |
| 42 | Mexico | Article 25(1), second sentence | |
| 43 | Morocco | Article 25(1), second sentence | |
| 44 | Netherlands | Article 26(1), second sentence | |
| 45 | North Macedonia | Article 26(1), second sentence | |
| 47 | Oman | Article 25(1), second sentence | |
| 48 | Pakistan | Article 26(1), second sentence | |
| 50 | Poland | Article 26(1), second sentence | |
| 52 | Qatar | Article 24(1), second sentence | |
| 53 | Romania | Article 27(1), second sentence | |
| 54 | Russia | Article 25(1), second sentence | |
| 55 | San Marino | Article 24(1), second sentence | |
| 56 | Saudi Arabia | Article 25(1), second sentence | |
| 57 | Serbia | Article 26(1), second sentence | |
| 58 | Singapore | Article 26(1), second sentence | |
| 59 | Slovak Republic | Article 25(1), second sentence | |
| 60 | Slovenia | Article 25(1), second sentence | |
| 61 | South Africa | Article 25(1), second sentence | |
| 62 | Spain | Article 26(1), second sentence | |
| 63 | Sweden | Article 25(1), second sentence | |
| 64 | Switzerland | Article 25(1), second sentence | |
| 65 | Thailand | Article 25(1), second sentence | |
| 66 | Tunisia | Article 24(1), second sentence | |
| 68 | Ukraine | Article 25(1), second sentence | |
| 69 | United Arab Emirates | Article 25(1), second sentence | |
| 73 | Uruguay | Article 26(1), second sentence | |
| 74 | Vietnam | Article 25(1), second sentence |
Notification of Listed Agreements Not Containing Existing Provisions
Pursuant to Article 16(6)(c)(i) of the Convention, Hungary considers that the following agreement does not contain a provision described in Article 16(4)(b)(i).
| Listed Agreement Number | Other Contracting Jurisdiction | |
| 42 | Mexico |
Pursuant to Article 16(6)(c)(ii) of the Convention, Hungary considers that the following agreements do not contain a provision described in Article 16(4)(b)(ii).
| Listed Agreement Number | Other Contracting Jurisdiction | |
| 4 | Austria | |
| 8 | Belgium | |
| 10 | Brazil | |
| 12 | Canada | |
| 18 | Egypt | |
| 42 | Mexico | |
| 49 | Philippines | |
| 51 | Portugal | |
| 53 | Romania | |
| 62 | Spain | |
| 64 | Switzerland | |
| 65 | Thailand | |
| 67 | Turkey | |
| 70 | United Kingdom | |
| 72 | United States |
Pursuant to Article 16(6)(d)(i) of the Convention, Hungary considers that the following agreements do not contain a provision described in Article 16(4)(c)(i).
| Listed Agreement Number | Other Contracting Jurisdiction | |
| 3 | Australia | |
| 21 | France |
Pursuant to Article 16(6)(d)(ii) of the Convention, Hungary considers that the following agreements do not contain a provision described in Article 16(4)(c)(ii).
| Listed Agreement Number | Other Contracting Jurisdiction | |
| 3 | Australia | |
| 8 | Belgium | |
| 10 | Brazil |
Reservation
Pursuant to Article 17(3)(a) of the Convention, Hungary reserves the right for the entirety of Article 17 not to apply to its Covered Tax Agreements that already contain a provision described in Article 17(2). The following agreements contain provisions that are within the scope of this reservation.
| Listed Agreement Number | Other Contracting Jurisdiction | Provision | |
| 1 | Albania | Article 9(2) | |
| 2 | Armenia | Article 9(2) | |
| 3 | Australia | Article 9(3) | |
| 5 | Azerbaijan | Article 9(2) | |
| 6 | Bahrain | Article 9(2) | |
| 7 | Belarus | Article 9(2) | |
| 11 | Bulgaria | Article 9(2) | |
| 12 | Canada | Article 9(2) | |
| 17 | Denmark | Article 9(2) | |
| 18 | Egypt | Article 9(2) | |
| 22 | Georgia | Article 9(2) | |
| 23 | Germany | Article 9(2) | |
| 25 | Hong Kong | Article 9(2) | |
| 26 | Iceland | Article 9(2) | |
| 27 | India | Article 9(2) | |
| 29 | Ireland | Article 9(2) | |
| 35 | Kuwait | Article 9(2) | |
| 37 | Liechtenstein | Article 9(2) | |
| 39 | Luxemburg | Article 9(2) | |
| 41 | Malta | Article 9(3) | |
| 42 | Mexico | Article 9(2) | |
| 44 | Netherlands | Article 9(2) | |
| 45 | North Macedonia | Article 9(2) | |
| 47 | Oman | Article 9(2) | |
| 48 | Pakistan | Article 9(2) | |
| 49 | Philippines | Article 8(2) | |
| 51 | Portugal | Article 9(2) | |
| 52 | Qatar | Article 9(2) | |
| 55 | San Marino | Article 9(2) | |
| 56 | Saudi Arabia | Article 9(2) | |
| 60 | Slovenia | Article 9(2) | |
| 61 | South Africa | Article 9(2) | |
| 63 | Sweden | Article 9(2) | |
| 64 | Switzerland | Article 9(2) | |
| 67 | Turkey | Article 9(2) | |
| 69 | United Arab Emirates | Article 10(2) | |
| 70 | United Kingdom | Article 9(2) | |
| 72 | United States | Article 9(2) |
Notification of Choice of Optional Provisions
Pursuant to Article 18 of the Convention, Hungary hereby chooses to apply Part VI.
Reservation
Pursuant to Article 19(12) of the Convention, Hungary reserves the right for the following rules to apply with respect to its Covered Tax Agreements notwithstanding the other provisions of Article 19:
a) any unresolved issue arising from a mutual agreement procedure case otherwise within the scope of the arbitration process provided for by the Convention shall not be submitted to arbitration, if a decision on this issue has already been rendered by a court or administrative tribunal of either Contracting Jurisdiction;
b) if, at any time after a request for arbitration has been made and before the arbitration panel has delivered its decision to the competent authorities of the Contracting Jurisdictions, a decision concerning the issue is rendered by a court or administrative tribunal of one of the Contracting Jurisdictions, the arbitration process shall terminate.
Reservation
