(1) Interest arising in a Contracting State and beneficially
owned by a resident of the other Contracting State shall be
taxable only in that other State.
(2) The term “interest” as used in this Article means income
from debt-claims of every kind, whether or not secured by
mortgage, and in particular, income from government securities
and income from bonds or debentures, including premiums and
prizes attaching to such securities, bonds or debentures.
Penalty charges for late payment shall not be regarded as
interest for the purpose of this Article. However, the term
“interest” does not include income dealt with in Article 10.
(3) The provisions of paragraph 1 shall not apply if the bene-
ficial owner of the interest, being a resident of a Contracting
State, carries on business in the other Contracting State in which
the interest arises, through a permanent establishment situated
therein and the debt–claim in respect of which the interest is paid
is effectively connected with such permanent establishment.
In such case the provisions of Article 7 shall apply.
(4) Interest shall be deemed to arise in a Contracting State
when the payer is a resident of that State. Where, however, the
person paying the interest, whether he is a resident of a
Contracting State or not, has in a Contracting State a permanent
establishment in connection with which the indebtedness on
which the interest is paid was incurred, and such interest is borne
by such permanent establishment, then such interest shall be
deemed to arise in the State in which the permanent establish-
ment is situated.
(5) Where, by reason of a special relationship between the
payer and the beneficial owner or between both of them and
some other person, the amount of the interest, having regard to
the debt-claim for which it is paid, exceeds the amount which
would have been agreed upon by the payer and the beneficial
owner in the absence of such relationship, the provisions of this
Article shall apply only to the last mentioned amount. In such
case, the excess part of the payments shall remain taxable
according to the laws of each Contracting State, due regard
being had to the other provisions of this Agreement.
Citation to select or copy
Germany / Hungary; BGBl. 2011 II S. 919; edition de-hungary-2011-base | BGBl. 2011 II S. 919 | Signed: 2011-02-28 | Gazette publication: 2011-10-07; article 11; English; unreviewed source text, current applicability unverified; /editions/de-hungary-2011-base/en/articles/article-11/
Disclaimers
Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.
Language switching retains source identifiers only. This is not reviewed legal or translational equivalence.
Page links are source references, not verified paragraph correspondence. Formatting and extraction errors may remain.
Noindex is not access control. This is a research preview, not a statement of authoritative or current law.
de-hungary-2011-base | BGBl. 2011 II S. 919 | Signed: 2011-02-28 | Gazette publication: 2011-10-07
Text available here
Deutsch, English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Gazette publication date
2011-10-07
Provenance
agent source-triage of pinned original; neither date is treaty entry/application
Signature date
2011-02-28
Edition notes and known limitations
Original source edition; not a verified current-law consolidation. Original base edition only; current law NOT verified. Integral protocol retained separately, not merged into the final article. Later changes and 2026 developments are not exhaustively verified. KNOWN MLI EFFECTS OMITTED: audit records general application from 2025-01-01 and Part VI from 2024-11-01; neither is incorporated. Tax-specific MLI application remains unreviewed. Replaces agreement signed 1977-07-18; exact transitional effects remain unreviewed. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Integral protocol retained separately, not merged into the final article. Later changes and 2026 developments are not exhaustively verified. KNOWN MLI EFFECTS OMITTED: audit records general application from 2025-01-01 and Part VI from 2024-11-01; neither is incorporated. Tax-specific MLI application remains unreviewed. Replaces agreement signed 1977-07-18; exact transitional effects remain unreviewed. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force. Known related/later instruments NOT included in this source (agent triage, not exhaustive): BEPS-MLI; general application from: 2025-01-01; part VI general application from: 2024-11-01
The original signing clause identifies German, Hungarian and English as authentic. Only German and English are supplied; the authentic Hungarian version is NOT included. The clause gives English precedence in divergent interpretation of the German and Hungarian texts. Unreviewed coordinate-based machine transcription of this original source edition only. Printed line breaks, hyphens and uncertain token spacing are retained, not silently corrected. Treaty preamble, closing formula, protocol and shared signatures are separate retained assets, not part of the last article. Full supplements: /review/de-hungary-2011-base/. PDF page links identify pages, not verified paragraph correspondence. Signed 2011-02-28; consent law 2011-09-30; Gazette publication 2011-10-07; treaty entry into force UNRESOLVED in pinned audit (retained official-article audit evidence); general application from 2012-01-01 (roster, not universal tax-specific start). Encoding-recovery method: only independently evidenced source font code00 /space Unicode mappings U+0007 to U+0020 changed in a separately hashed derivative. CFF blank glyphs, 278-unit advances, unchanged decoded page content streams and 22/22 identical page renders evidence this mapping. Word regrouping is logged; every nonspace character is conserved in sequence within its physical source line. No generated treaty wording and no OCR.