Ministry of Finance clarifies tax treatment of Greek-source royalties in tax treaties with Czech Republic and Hungary

The Greek Ministry of Finance issued recently a Ministerial Circular (POL 1144/2012), in order to clarify the tax treament of Greek-source royalties payable to tax residents of the Czech Republic or Hungary. According to this circular, the wording of article 12 of the Czech Republic - Greece Income Tax Treaty (1986) and the Greece - Hungary Income and Capital Tax Treaty (1983) does not provide for the exclusive taxation of royalties by the residence state, therefore the …