U.S.A./Hungary Income Tax Treaty Terminated
The U.S. Treasury Department recently announced that the U.S.A./Hungary Income Tax Treaty (in force since 1979) is officially terminated, effective January 8, 2023.
The cessation of the agreement is a direct result of Hungary’s opposition of the European Union’s implementation of a global corporate minimum income tax rate of 15%.
The U.S. Treasury’s position is that Hungary’s 9% rate – less than half of the U.S. 21% rate – results in a unilateral treaty benefit to Hungary. The U.S.A. is using all avenues to pressure countries to implement a 15% minimum rate, which has already been agreed to by nearly 140 countries. Hungary argues that a rate increase will make it difficult to attract commerce and employment within its borders.
For global mobility professionals, the dissolution may result in future higher tax costs for short-term assignments between the two countries.
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