Companies incorporated in Hungary are
subject to corporate tax on their worldwide profits. A company
not incorporated in Hungary that has its place of effective management
in Hungary is regarded as a Hungarian resident for corporate
tax purposes and, accordingly, is subject to corporate tax on
its worldwide profits. If a double tax treaty applies, the provisions
of the treaty determine residence. Foreign companies carrying out
taxable activities in Hungary through a permanent establishment
are subject to corporate tax on their net profits derived from
Hungarian sources.