Australian Tax Treaties
Hungarian Agreement
AGREEMENT BETWEEN AUSTRALIA AND THE REPUBLIC OF HUNGARY FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME
ARTICLE 23
Source of Income
Income, profits or gains derived by a resident of a Contracting State which, under any one or more of Articles 6 to 8, 10 to 17, 19 and 22, may be taxed in the other Contracting State shall, for the purposes of Article 24 and of the income tax laws of the respective States be deemed to be income from sources in that other State.
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) has modified the application of this tax treaty. A synthesised text of the MLI and this tax treaty is available to facilitate the understanding of how the MLI modifies this tax treaty.
Income, profits or gains derived by a resident of a Contracting State which, under any one or more of Articles 6 to 8, 10 to 17, 19 and 22, may be taxed in the other Contracting State shall, for the purposes of Article 24 and of the income tax laws of the respective States be deemed to be income from sources in that other State.
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