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of <h1>Taxation of Interest Under Article 11 of Hungary's DTAA: 10% Cap, Exemptions for Certain Banks and Entities</h1> Article 11 of the Double Tax Avoidance Agreement (DTAA) between Hungary and another Contracting State addresses the taxation of interest. Interest arising in one Contracting State and paid to a resident of the other may be taxed in both states, but the tax in the source state is capped at 10% if the recipient is the beneficial owner. Exemptions from taxation in the source state apply to interest beneficially owned by government entities, central banks, and certain banks like the Hungarian Exim Bank and the Export Import Bank of India. The article defines 'interest' and outlines conditions where the general provisions do not apply, especially involving permanent establishments or special relationships affecting interest amounts.
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