Austria's Ministry of Finance has published the synthesized text of the 1975 income and capital tax treaty with Hungary as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The synthesized text has been prepared based on the reservations and notifications (MLI positions) submitted by the respective countries. The authentic legal texts of the tax treaty and the MLI take precedence and remain the legal texts applicable.
The MLI applies for the 1975 Austria-Hungary tax treaty (German language):
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2022; and
- with respect to all other taxes for taxes levied with respect to taxable periods beginning on or after 1 January 2022.
Notwithstanding the above, the provisions of Part VI (Arbitration) of the MLI have effect with respect to the treaty for cases presented to the competent authority of a Contracting State on or after 1 July 2021, and for cases presented prior to that date to the extent agreed by the competent authorities.
MLI synthesized texts of Austria's tax treaties can be found on the Ministry of Finance treaty webpage.