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]
Biežāk uzdotie jautājumi
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.
Pārrobežu rezultāti ir atkarīgi no nodokļu rezidences, kontrolētu ārvalstu sabiedrību noteikumiem un reālas saimnieciskās būtības – ar struktūru uz papīra nepietiek. Skatīt atrunu zemāk.
Avoti
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