IN WITNESS WHEREOF the undersigned, duly authorized hereto, have signed this Convention.

DONE in duplicate in Budapest this 25th day of May 1983, in the English language, both texts being equally authentic.

PROTOCOL

At the signing today of the Convention between the Government of the Hungarian People’s Republic and the Government of the Hellenic Republic for the avoidance of double taxation with respect to taxes on income and on capital the undersigned have agreed upon the following provisions which shall form an integral part of the Convention.

Ad Articles 5 and 7

According to the information given by the Hellenic delegation the provisions of paragraph (3), Article 5, subparagraph (2) of paragraph (5), Article 5 fully correspond to the general conditions of the Conventions for the avoidance of double taxation concluded recently by the Hellenic Republic.

No profit can be attributed to the permanent establishment by reason of delivery of goods or merchandise, machinery or equipment notwithstanding that the delivery was carried out by the enterprise or by a third person.

It is understood that the term “place of business” includes also a place of production.

Concerning Article 7 where a building site, construction, installation or assembly project constitute a permanent establishment only those profits can be attributed to that permanent establishment which derive from the activity of the building site, construction, installation or assembly project.

Ad Article 10

It is agreed that, since the difference between the provisions of subparagraph a) and those of subparagraph b) of paragraph (2) of Article 10 is based on the fact that according to the Hellenic income tax on legal entities as in force at the date of signature of the Convention dividends paid by a company which is a resident of the Hellenic Republic are deductible in the computation of the profits of the company paying the dividends, the two Governments will undertake the review of the provisions of paragraph 2 when the basis of such difference no longer exists. Until the review has been completed the aggregate Hellenic tax on dividends and on the profits out of which the dividends are paid shall not exceed 45%.

IN WITNESS WHEREOF the undersigned, duly authorized thereto, have signed this Protocol.

DONE in duplicate in Budapest this 25th day of May 1983, in the English language both texts being equally authentic.