Key facts
| Item | Rate / rule |
|---|---|
| Corporate income tax | 9% - lowest in the EU |
| Withholding on payments to non-resident companies | 0% - dividends, interest, royalties |
| Local business tax (HIPA) | Up to 2% of net revenue, municipal |
| Dividends to resident individuals | 15% PIT + 13% social contribution up to a cap |
| Optional small-business tax (KIVA) | 10%, replaces CIT and the 13% social contribution |
Why the 0% withholding is unusual
Inside the EU, dividends between related companies already flow tax-free under the Parent–Subsidiary Directive - but only with conditions, typically a 10% holding kept for one or two years, and only between member states. Outside those conditions, withholding bites: 19% in Poland, 25% in Portugal, 26% in Italy, 26.375% in Germany. Hungary skips the conditions entirely: any payment of dividends, interest or royalties to a non-resident company leaves at 0%, whether the recipient is in the EU, the US or anywhere else.[1][5]
Combined with the 9% rate, that makes Hungary a natural intermediate layer: profit taxed once at 9% (plus up to 2% municipal business tax) can move onward to owners or group companies without a second toll at the border.[2]
The individual layer
For a Hungarian resident owner the picture is still good but not zero: dividends carry 15% personal income tax plus a 13% social contribution capped at 24 times the monthly minimum wage per year - roughly 22.7% all-in on top of the 9%. Foreign individual owners instead pay their home country’s dividend tax; Hungary itself withholds nothing on the way out to companies, and payments to individuals follow treaty rules.[3]
The catch
Other countries have noticed. The Netherlands charges a 25.8% conditional withholding tax on interest, royalties and dividends paid to affiliated companies in jurisdictions with a statutory rate of 9% or less - Hungary sits exactly on that line. Anti-abuse rules under ATAD (CFC attribution, the general anti-abuse rule) and treaty principal-purpose tests all target empty conduit structures: a Hungarian layer works only with real functions, people and decision-making in Hungary. And a holding company that is all mailbox is resident wherever it is actually run.[4][6]
Συχνές ερωτήσεις
Does Hungary withhold tax on dividends paid to foreign companies?
No - Hungary levies no withholding tax on dividends, interest or royalties paid to non-resident companies, without EU-directive holding-period or ownership conditions.
Is 9% really the whole corporate burden?
Not quite: municipalities add a local business tax of up to 2% of net revenue, and medium and large firms pay a 0.3% innovation contribution. A minimum tax base of 2% of revenue applies when reported profit is lower.
Why does the Dutch conditional withholding tax matter here?
It shows the direction of travel: payments from the Netherlands to affiliates in jurisdictions taxed at 9% or less face 25.8% withholding. Structures that merely route money through low-tax layers are being priced out by source countries.
Τα διασυνοριακά αποτελέσματα εξαρτώνται από τη φορολογική κατοικία, τους κανόνες για τις ελεγχόμενες αλλοδαπές εταιρείες και την πραγματική οικονομική υπόσταση - μια δομή στα χαρτιά δεν αρκεί. Δείτε την αποποίηση ευθύνης παρακάτω.
Πηγές
Παραπομπές με αρίθμηση που αναφέρονται σε όλο αυτό το άρθρο. Οι νόμοι συνδέονται με κωδικοποιημένα κείμενα στο επίσημο μητρώο.