Not in his case since he is the developer and work is performed in Austria.
However the thing that make the Cyprus contruct work is paragraph 8 of article 7 of the
DTT between Cyprus and Austria that says "
(8) The term "profits" as used in this Article shall include profits of a partner from his participation in a partnership, including participation in a a silent partnership."
If you look at the
DTT between Cyprus and Hungary you'll see that there's paragraph 6 of article 7 that says "
(6) The provisions of this Article shall also apply to shares in profits arising from participation as a silent partner in an enterprise."
OP should seek professional tax advice but that line could mean that if he goes and form a company in which he is only an investor and job is performed through a permanent establishment in Hungary, he could potentially pay only 9% CIT in Hungary and then as per paragraph 6 "s
hares in profits arising from participation as a silent partner in an enterprise" should be tax free but i'm 100% speculating.
Obviosly OP should hire somebody in HU and rent an office BUT he potentially could commute to Sopron which is one hour drive from Wien, cross the border without anybody knowing and perform the work himself alongside the employee.