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Commentary

6.2 Double tax relief

Hungary

Hungary has concluded around 80 double tax treaties. The treaties with Russia and Belarus have had some of their articles suspended in 2024 (Gov.ru, nav.gov.hu). Also, the treaty with the USA has been terminated (IRS.gov).

Taxation rights of the involved jurisdictions in case of employment depend on:

  1. Ìý

    •ÌýÌýÌýÌý the source of the income

  2. Ìý

    •ÌýÌýÌýÌý the tax residency of the beneficiary, and

  3. Ìý

    •ÌýÌýÌýÌý the place of the work

Generally, based on the OECD model treaty, earnings originating from employment are taxable according to the tax residency of the employee.

As an exception, the right of taxation remains in the country that the work is being carried out in, if the following conditions are completed:

  1. Ìý

    •ÌýÌýÌýÌý staying in the host country for work does not exceed 183 days in the tax year or in any 12-month period, and

  2. Ìý

    •ÌýÌýÌýÌý salary is paid by or in the name of a non-resident employer, and

  3. Ìý

    •ÌýÌýÌýÌý a non-resident

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