Hungary
A. Progress in the implementation of the minimum standard
Hungary has 81 tax agreements, as reported in its response to the Peer Review questionnaire.
Hungary signed the MLI in 2017 and has not listed its agreements with Albania, Armenia, Bahrain, Bosnia-Herzegovina, Montenegro, North Macedonia, Oman and the United Arab Emirates. These agreements will therefore not, at this stage, be modified by the MLI. Albania, Armenia, Bosnia-Herzegovina, North Macedonia, Oman and the United Arab Emirates have listed their agreements with Hungary under the MLI.
Hungary indicated in its response to the Peer Review questionnaire that the agreements not listed under the MLI were concluded with treaty partners that were not Ad Hoc Group members at the time of Hungary’s signature. Hungary further indicated that it is not concerned by treaty shopping with respect to those agreements.
Hungary is implementing the minimum standard through the inclusion of the preamble statement and the PPT.1
The agreements that will be modified by the MLI will come into compliance with the minimum standard once the provisions of the MLI take effect.
B. Implementation issues
Hungary’s listed agreements under the MLI will start to be compliant after Hungary’s ratification of the MLI. Hungary indicated that it expected to deposit its instrument of ratification of the MLI early in 2021.
As mentioned above, Hungary has not listed its agreements with Albania, Armenia, Bahrain, Bosnia Herzegovina, Montenegro, North Macedonia, Oman and the United Arab Emirates under the MLI. Listing the agreements under the MLI or entering into bilateral renegotiations to implement the minimum standard would ensure that the minimum standard could be implemented in those non-covered agreements.
Note
← 1. For its agreements listed under the MLI, Hungary is implementing the preamble statement (Article 6 of the MLI) and the PPT (Article 7 of the MLI).