DoubleTaxationPakistan – Hungary tax treaty: residence, 183 days, rates
Convention between the Islamic Republic of Pakistan and the Republic of Hungary for the avoidance of double taxation with respect to taxes on income (signed on 24 February 1992), as amended by the Protocol of 2020
- Signed: 24/02/1992
- In force since: 06/02/1994
- Official text
If both countries treat you as resident
- Dual-resident individual: (a) resident of the State in which he has a permanent home available to him; if he has one in both States — the State with which his personal and economic relations are closer (centre of vital interests); (b) if that State cannot be determined, or if he has not a permanent home available to him in either State — the State in which he has an habitual abode; (c) habitual abode in both States or in neither — the State of which he is a national; (d) national of both or of neither — the competent authorities settle the question by mutual agreement. Art. 4(2) Pakistan–Hungary Convention (1992)
- MLI in force for Pakistan from 1 April 2021 and for Hungary from 1 July 2021; it adds the new preamble (Art. 6 MLI) and the principal purpose test (Art. 7 MLI) only. Art. 4, 16 and 24 are unchanged. The authentic texts prevail. Synthesised text of the MLI and the Pakistan–Hungary Convention (FBR)
- Pakistan: signed 24 February 1992, promulgated by Act II of 1996, applicable from 1 January 1995; amending protocol (note verbal) of 14 July 2020, promulgated by Act CIII of 2020, applicable from 1 January 2022. NAV — Double Taxation Treaties of Hungary (as of 01/01/2026)
- If you have no permanent home available in either State, the treaty goes straight to habitual abode (the centre of vital interests step applies only where there is a home in both States). Art. 4(2)(b) Pakistan–Hungary Convention (1992)
- Centre of vital interests: the State with which your personal and economic relations are closer. Art. 4(2)(a) Pakistan–Hungary Convention (1992)
- Habitual abode in both States or in neither — resident of the State of which you are a national; national of both or of neither — the competent authorities settle the question by mutual agreement. Art. 4(2)(c), (d) Pakistan–Hungary Convention (1992)
Income: who taxes it
| Income | Treaty rule | Article |
|---|---|---|
| Salary (employment) | The country where the work is done may tax it. Exempt if all apply: no more than 183 days in the tax year; the employer is not resident there; the pay is not borne by its permanent establishment there. | Art. 16(2) |
| Self-employment, business, services | Country of residence; the other country taxes profits of a permanent establishment (fixed base) there, or if your stay there reaches 183 days in the tax year. | Art. 7, Art. 15 |
| Pension | Only the country of residence. | Art. 19 |
| Government service | Usually only the paying country; exception: service in the other country by its national. | Art. 20 |
| Government service pension | Usually only the paying country; exception: service in the other country by its national. | Art. 20 |
| Rent from real estate | The country where the property is located may tax; the country of residence relieves double taxation. | Art. 6 |
| Dividends | Source country: at most 20%; the country of residence relieves double taxation. | Art. 10(2)(b) |
| Interest (deposits, bonds, loans) | Source country: at most 15%; the country of residence relieves double taxation. | Art. 11(2) |
| Royalties (copyright, licences) | Source country: at most 15%; the country of residence relieves double taxation. | Art. 12(2) |
| Technical, consulting, management services | Source country: at most 15%; the country of residence relieves double taxation. | Art. 13(2)–(3) |
| Sale of property or shares | Real estate: the country where it is located may tax. Shares of companies deriving their value mainly from real estate: the same. Other property: under certain conditions the source country may also tax (see the article). | Art. 14 |
| Other income | The source country may tax; the country of residence relieves double taxation. | Art. 23 |
How double taxation is relieved
- Hungary: exemption: the income is not taxed but counts towards the rate on other income (credit for dividends, interest, royalties, fees for technical services) Art. 24(a)
- Pakistan: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 24(b)
Data checked: 10/11/2026. A short summary for individuals; the full conditions, exceptions and protocols are in the treaty text. General information, not legal advice.