In Hungary, the taxation of dividends is structured differently for domestic and foreign shareholders, and it also depends on whether the recipient is an individual or a corporate entity. Here is an overview of how dividends are taxed in Hungary:

1. Dividends Paid to Domestic Shareholders

Individual Shareholders

• Personal Income Tax (PIT): Dividends paid to individual residents are subject to a personal income tax rate of 15%.
• Social Contribution Tax: Dividends are also subject to a social contribution tax of 13%, but only up to a cap. The cap is based on the individual's annual income, ensuring that total social contributions do not exceed the annual maximum.

Corporate Shareholders

• Corporate Income Tax (CIT): Dividends received by Hungarian resident companies are generally exempt from corporate income tax. This exemption helps avoid double taxation of profits.

2. Dividends Paid to Non-Resident Shareholders

Individual Shareholders

• Withholding Tax: Hungary does not impose withholding tax on dividends paid to non-resident individuals. This is beneficial for foreign investors, as it simplifies tax compliance.

Corporate Shareholders

• Withholding Tax: Similarly, there is no withholding tax on dividends paid to non-resident companies. This makes Hungary an attractive destination for international investments.

3. Double Taxation Agreements (DTAs)

Hungary has an extensive network of double tax treaties with numerous countries. These treaties often provide reduced tax rates or exemptions on dividends, thus preventing double taxation. The specific rates and conditions depend on the terms of the applicable treaty.

4. EU Parent-Subsidiary Directive

Under the EU Parent-Subsidiary Directive, dividends paid by a Hungarian subsidiary to an EU parent company are exempt from withholding tax, provided certain conditions are met, such as a minimum ownership percentage and holding period.

Summary of Key Points

• Resident Individuals: 15% personal income tax and 13% social contribution tax (up to a cap).
• Resident Companies: Dividends are generally exempt from corporate income tax.
• Non-Resident Individuals and Companies: No withholding tax on dividends.
• Double Tax Treaties: May provide further tax benefits or exemptions.
• EU Parent-Subsidiary Directive: Exempts qualifying dividends from withholding tax.

Practical Considerations

• Tax Planning: Businesses and investors should consider the implications of both domestic tax laws and international treaties to optimize their tax positions.
• Compliance: Proper documentation and adherence to regulatory requirements are essential to benefit from exemptions and reduced tax rates.
• Professional Advice: Consulting with tax advisors or legal experts familiar with Hungarian and international tax laws can help navigate the complexities and ensure compliance.

By understanding the dividend taxation rules in Hungary and leveraging international agreements, businesses and investors can effectively manage their tax obligations and take advantage of available benefits.