SolvedDT9253 | Double Taxation Relief Manual: Hungary: treaty summary
From HM Revenue & Customs · Double Taxation Relief Manual
The table summarises the provisions of the treaty in force. Where a percentage rate is shown, this rate is the ‘treaty rate’ and does not reflect taxes chargeable under the domestic law of either state before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which the UK and Hungary are permitted to tax income in the relevant categories under the treaty. Rates chargeable under the domestic law of either state may be higher or lower.
In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.
| Subject | Comments | Article |
|---|---|---|
| Portfolio dividends | 10% (Note 1) | 10 |
| Dividends on direct investments | 0% | 10 |
| Conditions for lower rate on dividends on direct investments | The beneficial owner must be a company which controls directly or indirectly at least 10% of the voting power of the paying company | 10 |
| Property income dividends | 15% | 10 |
| Interest | 0% | 11 |
| Royalties | 0% | 12 |
| Government pensions | Taxable only in Hungary unless the individual is a resident and national of the UK | 18 |
| Other pensions | Taxable only in the UK | 17 |
| Arbitration | No | N/A |
Note 1: Dividends beneficially owned by a pension scheme are taxable only in the state in which the pension scheme is resident.