2014. évi LII. törvény a Magyarország Kormánya és a Szaúd-Arábiai Királyság Kormánya között a kettős adóztatás elkerüléséről és az adóztatás kijátszásának megakadályozásáról a jövedelem- és vagyonadók

Article 4

of the Convention, it is understood that the term „resident of a Contracting State” also includes any person organized under the laws of a Contracting State, that is not liable to tax in that State and is established and maintained in that State either: (

1. a)exclusively for a religious, charitable, educational, scientific or other similar public purpose; or (
2. b)to provide pensions or other similar remuneration to employees. 3.

Article 7

of the Convention, it is understood that: (

1. a)the business profits derived by an enterprise of a Contracting State from the exportation of merchandise to the other Contracting State shall not be taxed in that other Contracting State. Where export contracts include other activities carried on through a permanent establishment in the other Contracting State profits derived from such activities may be taxed in the other Contracting State; (
2. b)the term „business profits” includes, but is not limited to income derived from manufacturing, mercantile, banking, insurance, operation of inland transportation, furnishing of services and rental of movable property. Such a term does not include the performance of personal services by an individual either as an employee or in an independent capacity. 4.

Article 26

of the Convention, it is understood that the information exchanged according to the provisions of the said Article shall be used only for tax purposes as specified therein.

1. The Government of Hungary understands that the obligations of Hungary under this Convention are consistent with its obligations as a member of the European Union. However, if Hungary finds out in the future that its obligations under this Convention are inconsistent with the requirements that apply to Hungary as a member of the European Union, both Contracting States may consult each other about the possible amendments of the Convention. In witness whereof the undersigned, being duly authorized thereto, have signed this Protocol. Done in duplicate at Riyadh on 23 March 2014 in the Hungarian, Arabic and English languages, all texts being equally authentic. In case of divergence of interpretation, the English text shall prevail. For the Government of Hungary For the Government of the Kingdom of Saudi Arabia (signatures)”
2. §