Treaty detail
United States - Hungary tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1979-02-12
Effective
1979-09-18
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 5%
Following the 2024 reactivation of the 1979 treaty after termination of the 2010 replacement treaty, the original 1979 framework rates apply. The 5 percent corporate rate generally depends on direct ownership of at least 10 percent of the voting stock, subject to article-level review.
Interest
Rate: 0%
The 1979 treaty generally provides zero-percent source-country interest withholding. Beneficial-ownership and qualifying-status conditions remain subject to article-level review.
Royalties
Rate: 0%
The 1979 treaty generally eliminates source-country withholding on qualifying royalties across the major copyright, patent, and know-how categories.
Permanent establishment
Construction threshold: more than 24 months under the 1979 treaty framework
Dependent-agent analysis under the 1979 wording remains important where a person habitually concludes contracts on behalf of the enterprise.
Other treaty flags
The reactivated 1979 Hungary treaty generally allocates private pensions to the residence state. Practitioners should confirm current treatment given the unusual reactivation history.
Seeded article summaries
Article 4
Residence
Defines treaty residence under the reactivated 1979 treaty framework.
The Hungary treaty situation is unusual because the 2010 replacement treaty was terminated and the original 1979 treaty applies again as of 2024. Residence analysis must reference the 1979 text rather than the lapsed 2010 framework.
Article 5
Permanent Establishment
Sets the business-presence threshold for source-country taxation under the 1979 framework.
The 1979 Hungary treaty includes older-style PE definitions that should be confirmed against the current treaty text rather than the lapsed 2010 framework. Article-level review is especially important here.
Article 7
Business Profits
Generally reserves business profits to the residence state absent a permanent establishment in the other state.
This is the operating-rule article once the PE analysis is complete. Under the reactivated 1979 framework, analysis is more textually constrained than under newer U.S. treaties.
Article 10
Dividends
Provides reduced source-country withholding rates for qualifying dividends.
The 1979 Hungary dividend article supports the standard 15 percent and 5 percent rates with conditions that include direct-ownership thresholds. Practitioners should confirm rates against the current treaty text following the 2024 reactivation.
Article 11
Interest
Generally eliminates source-country withholding on qualifying interest.
Interest under the reactivated 1979 Hungary treaty is generally not subject to source-country withholding. Beneficial-ownership and qualifying-status conditions remain subject to article-level review.
Article 12
Royalties
Generally removes source-country withholding on qualifying royalties.
The royalty article under the 1979 Hungary treaty is one of the clearest practical benefits. The zero-percent result depends on beneficial ownership and falls within the major royalty categories.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–GB treaty
- TreatyUS–CA treaty
- TreatyUS–DE treaty
- TreatyUS–FR treaty
- TreatyUS–JP treaty
- TreatyUS–NL treaty
- TreatyUS–AU treaty
- TreatyUS–KR treaty
Primary sources
- Hungary treaty documents pageVerified 2026-05-20
- Official U.S.-Hungary treaty PDFVerified 2026-05-20
- IRS Tax Treaty Table 1Verified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.