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 source state may also impose withholding tax on outbound royalties in application of its domestic legislation. The Ministry of Finance mentions that it adopts with regard to...