The existing taxes to which the Convention shall apply are:

• in Bahrain, to income tax payable under Bahrain Legislative Decree No. 22/1979; and

• in Hungary:

(i) the personal income tax;

(ii) the corporate tax

The treaty's main provisions are as follows:

Permanent establishment

The term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. A building site, a construction, assembly or installation project constitutes a permanent establishment only if it lasts more than twelve months.

The term permanent establishment covers as well:

• a mine, an oil or gas well, a quarry or any other place of extraction of natural resources;

• a refinery;

• a sales outlet; and

• a warehouse in relation to a person providing storage facilities for others.

Dividends