Japan's Ministry of Finance has published the synthesized text of the 1980 income tax treaty with Hungary as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). A summary of the application of the MLI has also been published. The synthesized text is solely for the purpose of facilitating the understanding of the application of the MLI to the treaty and does not constitute a source of law. The authentic texts of the Agreement and the MLI are the only legal texts applicable.

The MLI applies for the 1980 Japan-Hungary tax treaty:

• 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 levied by that Contracting State, 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.

Click the following link for the Ministry of Finance's webpage on the BEPS MLI for more information.