Communication from the Ministry of Foreign Affairs No. 103 / 1999 Coll.

Q: Is Communication from the Ministry of Foreign Affairs No. 103 / 1999 Coll. still valid?

Yes, Communication from the Ministry of Foreign Affairs No. 103 / 1999 Coll. is still valid and effective.

103

COMMUNICATION

Ministry of Foreign Affairs

The Ministry of Foreign Affairs states that on 30 June 1997 a Treaty was signed in Kiev between the Government of the Czech Republic and the Government of Ukraine to avoid double taxation and prevent tax evasion in the field of income and property taxes.

The Parliament of the Czech Republic agreed to the Treaty and the President of the Republic ratified the Treaty.

The Treaty entered into force pursuant to Article 28 (1) of the Treaty on 20 April 1999 and its provisions shall be implemented in accordance with paragraph 1 (a) and (b). According to paragraph 2 of that Article, the date on which this Treaty is to be implemented shall cease to be the following in relations between the Czech Republic and Ukraine:

Treaty on the prevention of double taxation of income and property of natural persons, signed in Miskovci on 27 May 1977, published under No 30 / 1979 Coll.,

and

Treaty on the prevention of double taxation of corporate income and property, signed at Ulanbatar on 19 May 1978, published under No 49 / 1979 Coll.

The Czech version of the Treaty is hereby published at the same time. The English version of the Treaty, which is relevant for its interpretation, can be consulted by the Ministry of Foreign Affairs and the Ministry of Finance.

TREATY

between the Government of the Czech Republic and the Government of Ukraine on the avoidance of double taxation and tax evasion in the field of income and property taxes

Government of the Czech Republic and Government of Ukraine,

Desiring to conclude a contract to avoid double taxation and prevent tax evasion in the field of income and property taxes and confirming their efforts to develop and deepen economic relations,

agree as follows:

Persons to whom the Treaty applies

This contract shall apply to persons resident in one or both Contracting States (residents).

Taxes to which the Treaty applies

1. This Treaty shall apply to income and property taxes levied on behalf of each of the Contracting States or its lower administrative departments or local authorities, whatever the method of collection.

2. All taxes levied on total income, on total assets or on parts of income or on assets, including taxes on profits from the disposal of movable or immovable property, taxes on total wages or salaries paid by undertakings as well as taxes on the increase of assets, shall be regarded as income and property taxes.

3. the taxes covered by this Treaty are:

(a) for Ukraine:

(i) company profit tax; and

(ii) income tax on citizens;

(hereinafter referred to as "Ukrainian tax ');

(b) for the Czech Republic:

(i) income tax on natural persons;

(ii) corporation tax;

(iii) real estate tax;

(hereinafter referred to as the "Czech tax ').

4. The contract will also apply to any tax of the same or, in principle, similar kind which will be imposed after the signature of the contract in addition to or instead of the current taxes. The competent authorities of the Contracting States shall communicate to each other any substantial changes to be made to their respective tax laws.

General definitions

1. For the purposes of this Treaty, unless the link requires a different interpretation:

(a) the term "Ukraine" shall refer to the territory of Ukraine, its continental shelf and its exclusive (seaside) economic zone, including any area outside the territorial waters of Ukraine which is or may be designated, in accordance with international law and under the legislation of Ukraine, as where the rights of Ukraine as regards the seabed and subsoil and their natural resources may be exercised;

(b) the term "Czech Republic" refers to the territory of the Czech Republic in which, under Czech law and in accordance with international law, the sovereign rights of the Czech Republic are exercised;

(c) the terms "one Contracting State" and "the other Contracting State" indicate, as appropriate, the Czech Republic or Ukraine;

(d) the term "national" means:

(i) any natural person who is a national citizen of a Contracting State;

(ii) any legal person, personal company or association established under the legislation in force in a Contracting State;

(e) the term "person" includes a natural person, company and any other association of persons;

(f) the term "company" refers to any legal person or rightholder treated as a legal person for taxation purposes;

(g) the terms "undertaking of one Contracting State" and "undertaking of the other Contracting State" indicate, according to the context, an undertaking operated by a resident of one Contracting State and an undertaking operated by a resident of the other Contracting State;

(h) the term "international transport" shall mean any transport of ships, boats, aircraft, road or rail vehicles operated by an undertaking of a Contracting State, except where a ship, boat, aircraft, road or railway vehicle is operated only between points in the other Contracting State;

(i) in the case of Ukraine, the term "competent authority" refers to the Ministry of Finance of Ukraine or its authorised representative and, in the case of the Czech Republic, the Minister of Finance of the Czech Republic or its authorised representative.

2. With regard to the application of the Treaty by a Contracting State, any expression not defined therein will have such meaning as it has under the law of that State, which regulates the taxes to which the Treaty applies, unless the link requires a different interpretation.

Resident

1. For the purposes of this Treaty, the term "resident of one Contracting State" shall mean any person who, under the law of that State, is subject to taxation in that State on account of his residence, permanent residence, place of administration, place of registration or any other similar criterion. However, this term does not include any person who is subject to taxation in that State solely because of income from resources in that State or of assets placed there.

2. Where, pursuant to paragraph 1 of this Article, a natural person is resident in both Contracting States, its status shall be determined as follows:

(a) that person is presumed to be resident in the Contracting State in which he has a permanent residence; where he has a permanent residence in both Contracting States, he is presumed to be resident in the Contracting State to which he has closer personal and economic relations (the Centre of Life Interests);

(b) where it cannot be determined in which Contracting State the person has a centre of his or her life interests, or where he or she does not have a permanent residence in any Contracting State, he / she shall be presumed to be resident in the Contracting State in which he / she normally resides;

(c) where that person normally resides in both Contracting States or in none of them, he shall be presumed to be resident in the Contracting State of which he is a national;

(d) where that person is a national of both Contracting States or of any of them, the competent authorities of the Contracting States shall amend the matter by mutual agreement.

3. Where a person other than a natural person is resident in both Contracting States in accordance with the provisions of paragraph 1 of this Article, he shall be presumed to be resident in the Contracting State in which his actual management is situated.

Permanent establishment

1. The term "permanent establishment" shall, for the purposes of this Treaty, indicate a permanent place of business through which the business of the undertaking is to be carried out in whole or in part.

2. the term "permanent establishment" includes in particular:

(a) the place of management;

(b) the plant;

(c) an office;

(d) the factory;

(e) workshop;

(f) a facility or building to investigate natural resources;

(g) mine, oil or gas site, quarry or any other place where natural resources are extracted;

(h) a warehouse or other facility used to supply goods.

3. the term "permanent establishment" also covers:

(a) construction site or construction, assembly or installation project or supervision associated with it, but only if such construction, project or supervision lasts for more than 12 months;

(b) the provision of services, including consultancy or management services, by an undertaking of one contracting State through employees or other personnel hired by the undertaking for that purpose, but only if the activities of that nature persist within the territory of the other contracting State for one or more periods exceeding three months in total in any 12-month period.

4. Notwithstanding the previous provisions of this Article, the term "permanent establishment 'shall not include:

(a) an establishment which is used only for the purpose of storing or issuing goods belonging to an undertaking;

(b) the supply of goods belonging to an undertaking which is maintained only for the purpose of storage or display;

(c) a stock of goods belonging to an undertaking which is maintained only for the purpose of processing by another undertaking;

(d) a permanent place of business which is maintained only for the purpose of purchasing goods or collecting information for the undertaking;

(e) a permanent place of business which is maintained solely for the purposes of advertising, the provision of information, scientific research or similar activities which are of a preparatory or ancillary nature to the undertaking;

(f) a permanent place of business which shall be maintained only for the exercise of any combination of the activities referred to in points (a) to (e) where the total activity of the permanent place of business resulting from that concentration is of a preparatory or auxiliary nature.

5. Where, irrespective of the provisions of paragraphs 1 and 2, a person - other than an independent representative to whom paragraph 6 applies - acts on the behalf of an undertaking in a Contracting State and has and usually uses an authorisation to conclude contracts on behalf of an undertaking, that undertaking shall be deemed to have a permanent establishment in that State in respect of all activities carried out by that person for the undertaking, provided that the activities of that person are not limited to the activities referred to in paragraph 4, which, if carried out through a permanent place of business, would not be based on that permanent establishment in accordance with the provisions of this paragraph.

6. An undertaking shall not be considered to have a permanent establishment in a Contracting State only because it carries out its business in that State through a broker, a general agent or any other independent agent, where such persons act in the course of their proper activities.

7. The fact that a company which is a resident of one Contracting State controls or is controlled by a company which is a resident of the other Contracting State or which carries out its activities in that other State (whether through a permanent establishment or otherwise) does not in itself constitute a permanent establishment of any other company.

Revenue from immovable property

1. Revenue received by a resident of one Contracting State from immovable property (including agricultural or forestry income) located in the other Contracting State may be taxed in that other State.

2. The term "immovable property" shall have such meaning as it may have under the law of the Contracting State in which the property is located. The term covers, in any case, the accessories of immovable property, the live and dead inventory used in agriculture and forestry, the rights to which the provisions of civil law applicable to land, the right to consume immovable property and the right to variable or fixed payments for mining or for the admission to mining of mineral deposits, springs and other natural resources apply. Ships, boats, aircraft, road and railway vehicles shall not be regarded as immovable property.

3. The provisions of paragraph 1 of this Article shall apply to revenue received from direct use, rental or any other use of immovable property.

4. Paragraphs 1 and 3 of this Article shall also apply to income from the immovable property of undertakings and to income from immovable property used for the pursuit of an independent profession.

Profits of enterprises

1. The profits of an undertaking of one Contracting State shall be subject to taxation only in that State if the undertaking does not carry out its activities in the other Contracting State through a permanent establishment situated there. If an undertaking carries out its activities in this way, the profits of the undertaking may be taxed in the other State, but only to the extent that they can be attributed to this permanent establishment.

2. Where an undertaking of a Contracting State carries on a standing activity in the other Contracting State through a permanent establishment situated there, it shall be attributed, subject to paragraph 3 of this Article, to profits in each Contracting State of that permanent establishment that could have been achieved if, as a separate undertaking, it had been engaged in the same or similar activities under the same or similar conditions and was wholly independent in contact with the undertaking of which it is a permanent establishment.

3. In calculating the profits of a permanent establishment, it shall be permitted to deduct the costs incurred for the objectives pursued by the permanent establishment, including management costs and general administrative expenses thus incurred, whether they arise in the State where the permanent establishment is located or elsewhere. However, such deduction shall not be allowed for amounts, if any, paid (other than against the reimbursement of actual expenditure) by the permanent head office of the undertaking or another of its offices in the form of royalties or other similar payments as compensation for the use of patents or other rights or in the form of commission for services provided separately or for management services or, except in the case of a banking undertaking, in the form of interest on money lent to a permanent establishment. Similarly, when determining the profits of a permanent establishment, the amounts charged (other than against the reimbursement of actual expenditure) by the permanent head office of an undertaking or another of its offices in the form of royalties or other similar payments shall not be taken into account in compensation for the use of patents or other rights or in the form of commission for services provided or management services provided or, except in the case of a banking undertaking, in the form of interest on the money lent to the head office of the undertaking or other offices.

4. Where, in a Contracting State in accordance with its law, it is customary to determine the profits to be added to a permanent establishment on the basis of the distribution of the company's total profits by its different parts, nothing in paragraph 2 of this Article shall preclude that Contracting State from determining the profits to be taxed by this normal distribution; However, the method of division used shall be such that the result complies with the principles set out in this Article.

5. A permanent establishment shall not make any profits on the basis that it only purchased goods for the undertaking.

(6) For the purposes of the preceding paragraphs, the profits to be added to a permanent establishment shall be determined in the same way each year, unless there are sufficient grounds for otherwise.

7. Where profits include parts of income which are dealt with separately in other Articles of this Treaty, the provisions of those Articles shall be without prejudice to the provisions of this Article.

International transport

1. Profit arising from the operation of ships, boats, aircraft, road or rail vehicles in international transport by a resident of a Contracting State shall be subject to taxation only in that State.

2. Profit from the operation of ships or aircraft in international transport for the purposes of this Article shall include:

(a) revenue from the hire of ships or aircraft without crew; and

(b) profits from the use, maintenance or rental of containers (including trailers and related container transport equipment) used for the carriage of goods, provided that such rental or use, maintenance or leasing, whichever case is the case, is incidental to the operation of ships or aircraft in international transport.

3. Paragraph 1 of this Article shall also apply to profits arising from participation in a pool, joint operation or an international operational organisation.

Associate undertakings

If

(a) the undertaking of one Contracting State participates, directly or indirectly, in the management, control or capital of the undertaking of the other Contracting State; or

(b) the same persons participate, directly or indirectly, in the management, control or capital of the undertaking of one Contracting State and of the undertaking of the other Contracting State

and if, in such cases, both undertakings are bound in their commercial or financial relations by conditions which have been negotiated or imposed on them and which differ from those which would have been negotiated between independent undertakings, any profits which, if not for those conditions, would have been achieved by one of the undertakings but have not been achieved, may be included in the profits of that undertaking and subsequently taxed.

Dividends

1. Dividends paid by a company resident in one Contracting State may be taxed in that other State.

2. However, such dividends may also be taxed in the Contracting State of which the company which pays them is resident under the law of that State, but where the beneficial owner of dividends is resident in the second Contracting State, the tax thus imposed shall not exceed:

(a) 5 per cent of the gross amount of dividends where the beneficial owner is a company (other than a personal company) which directly owns at least 25 per cent of the assets of the company paying dividends;

(b) 15 per cent of the gross amount of dividends in all other cases.

The competent authorities of the Contracting States shall, by mutual agreement, lay down the arrangements for applying such restrictions.

This paragraph shall not affect the taxation of the profits of the company on which dividends are paid.

3. The term "dividends" used in this Article refers to income from shares or other rights, with the exception of receivables, with a share in profits, as well as income from other rights in companies subject to the same tax regime as income from shares under the legislation of the State of which the company which divides profits is resident.

4. The provisions of paragraphs 1 and 2 shall not apply where the beneficial holder of dividends resident in one Contracting State is engaged in an industrial or commercial activity in the other Contracting State of which the dividend company is resident through a permanent establishment situated there or in that other State of an independent profession from a permanent base located there, and where the participation for which dividends are paid is actually linked to that permanent establishment or permanent base. In such a case, the provisions of Article 7 or Article 14 of this Treaty shall apply depending on the case.

5. Where a company which is resident in one Contracting State achieves profits or income from the other Contracting State, that other State may not tax dividends paid by the company unless such dividends are paid to the resident of that other State or that the participation for which dividends are paid actually relates to a permanent establishment or a permanent base located in that other State, or to subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or earnings distributed are wholly or partly derived from profits or income having a source in that other State.

Interest

1. Interest having a source in one Contracting State and paid to the resident of the other Contracting State may be taxed in that other State.

2. However, such interest may also be taxed in the Contracting State in which they have a source, under the legislation of that State, but if the beneficial owner of the interest is resident in the other Contracting State, the tax thus imposed shall not exceed 5 per cent of the gross amount of interest.

The competent authorities of the Contracting States shall, by mutual agreement, adapt the method of application of this restriction.

3. Notwithstanding the provisions of paragraph 2, interest having a source in one Contracting State and received and actually owned by the Government of the other Contracting State, including the lower administrative departments and local authorities of that State, the central bank or any financial institution wholly owned by that Government, or interest received on loans guaranteed by that Government, shall be exempt from taxation in the former Contracting State.

4. The term "interest 'used in this Article shall refer to income from claims of any kind, whether secured or not, by a lien on immovable property or having or not having the right to participate in the debtor's profit, and in particular to income from government securities and income from bonds or bonds, including premiums and winnings relating to such securities, bonds or bonds.

5. The provisions of paragraphs 1 and 2 shall not apply where the beneficial owner of interest resident in a Contracting State is engaged in an industrial or commercial activity in the second Contracting State in which the interest is received through a permanent establishment situated there or in that other State in an independent profession from a permanent base situated there, and where the claim on which interest is paid actually relates to that permanent establishment or permanent base. In such a case, the provisions of Article 7 or Article 14 of this Treaty shall apply depending on the case.

6. Interest shall be assumed to have a source in the Contracting State if the payer is the latter himself, the lower administrative department, the local office or resident of that State. However, if the interest payer, whether or not he is resident in a Contracting State, has a permanent establishment or permanent base in the Contracting State in conjunction with which the debt on which the interest is paid has been incurred and such interest is charged to such a permanent establishment or permanent base, it is assumed that such interest shall have a source in the State in which the permanent establishment or permanent base is located.

7. If the amount of interest relating to the claim on which it is paid exceeds, due to the special relationship between the payer and the beneficial owner or between both of them and any other person, the amount which the payer would have agreed with the beneficial owner if it had not been for such a relationship, the provisions of this Article shall apply only to that latter amount. In this case, the amount of payments exceeding it shall be taxed in accordance with the laws of each Contracting State, taking into account the other provisions of this Treaty.

Licence fees

1. Licensing fees having a source in one Contracting State and paid to the resident of the other Contracting State may be taxed in that other State.

2. However, such royalties may also be taxed in the Contracting State in which they have a source under the legislation of that State, but if the beneficial owner of the royalties is resident in the other Contracting State, the tax thus imposed shall not exceed 10 per cent of the gross amount of royalties.

The competent authorities of the Contracting States shall, by mutual agreement, adapt the method of application of this restriction.

3. The term "licence fees' used in this Article refers to payments of any kind received as compensation for use or as a right to use any copyright for the work of literary, artistic or scientific (including cinematographic films and films or recordings for radio or television broadcasting), any patent, trade mark, design or model, plan, secret formula or production process or any industrial, commercial or scientific establishment or for information (know- how) that relates to experience acquired in the field of industrial, commercial or scientific.

4. The provisions of paragraphs 1 and 2 of this Article shall not apply where the beneficial owner of a licence fee resident in a Contracting State is engaged in a source, industrial or commercial activity through a permanent establishment situated there or an independent profession located there in that other State, and where the right or property giving rise to royalties is actually linked to that permanent establishment or permanent establishment. In such a case, the provisions of Article 7 or Article 14 of this Treaty shall apply depending on the case.

5. Where the amount of royalties relating to the use, right or information for which they are paid exceeds, as a result of the special relationship between the payer and the beneficial owner or between both of them and any other person, the amount which the payer would have agreed with the beneficial owner if it had not been for such relations, the provisions of this Article shall apply only to that latter amount. In this case, the amount of payments exceeding it shall be taxed in accordance with the laws of each Contracting State, taking into account the other provisions of this Treaty.

6. Licensing fees are assumed to have a source in the Contracting State if the payer is the latter himself, the lower administrative department, the local office or resident of that State. However, where a licence fee payer, whether or not resident in a Contracting State, has a permanent establishment or permanent base in a Contracting State, in conjunction with which a licence fee has been paid, and such royalties are charged to such a permanent establishment or permanent base, those royalties shall be presumed to have a source in the State in which the permanent establishment or permanent base is located.

Profit from disposal

(1) Profit received by a resident of a Contracting State from the disposal of immovable property referred to in Article 6 of this Treaty, located in the other Contracting State, may be taxed in that other State.

(2) Profit from the disposal of shares in the share capital of a company whose assets remain, directly or indirectly, mainly from immovable property situated in a Contracting State may be taxed in that State.

3. Proceeds from the disposal of movable property which is part of the operating property of a permanent establishment which is owned by an undertaking of a Contracting State in the other Contracting State, or of movable property belonging to a permanent base which is owned by a resident of a Contracting State in the other Contracting State for the purpose of carrying out an independent occupation, including profits from the disposal of such permanent establishment (alone or together with the whole undertaking) or such permanent base, may be taxed in that other State.

4. Profit from the disposal of ships, boats, aircraft, road or railway vehicles operating in international transport by an undertaking of a Contracting State or the disposal of movable property which serves to operate such ships, boats, aircraft, road or railway vehicles shall be subject to taxation only in that Contracting State.

5. Profit from the disposal of any property other than those referred to in paragraphs 1, 2, 3 and 4 of this Article shall be subject to taxation only in the Contracting State of residence of which the transferee is resident.

Independent professions

1. Revenue received by a resident of a Contracting State from a professional or other independent activity shall be subject to taxation only in that State, except where such revenue may also be taxed in the other State:

(a) where the resident is regularly available in the second Contracting State to carry out his activities; in that case, only part of the income attributable to this permanent base may be taxed in that other State; or

(b) if his stay in the other State for one or more periods exceeds 183 days in total in any 12-month period; in that case, only that part of the income resulting from its activities in that other State may be taxed in that other State.

2. The following days shall be included in the calculation of the period referred to in paragraph 1 (b):

(a) all days of physical presence, including days of arrival and departure; and

(b) days spent outside the State of activities such as Saturdays and Sundays, national holidays, holidays and business trips directly linked to the pursuit of the activity of the beneficiary in that State, after which the activity in that State was continued.

3. The term "free profession" shall include the particular independent activities of scientific, literary, artistic, educational or teaching and the independent activities of doctors, lawyers, engineers, architects, dentists and accountants.

Employment

1. Salaries, wages and other similar remuneration received by a resident of a Contracting State on account of employment shall be subject, subject to the provisions of Articles 16, 18 and 19 of this Treaty, to taxation in that State only if the employment is not carried out in the other Contracting State. If there is employment there, the remuneration received may be taxed in that other State.

2. The remuneration received by a resident of a Contracting State on the grounds of employment in the other Contracting State shall, notwithstanding the provisions of paragraph 1 of this Article, be subject to taxation only in the former State if:

(a) the beneficiary shall be employed in the other State for one or more periods not exceeding 183 days in total in any 12-month period; and

(b) remuneration is paid by an employer or an employer who is not a resident of the other State; and

(c) remuneration shall not be borne by a permanent establishment or a permanent base held by an employer in the other State.

3. The following days shall be included in the calculation of the period referred to in paragraph 2 (a):

(a) all days of physical presence, including days of arrival and departure; and

(b) days spent outside the State of activities such as Saturdays and Sundays, national holidays, holidays and business trips directly linked to the employment of the beneficiary in that State, after which the activity in that State continued.

4. The term "employer" referred to in paragraph 2 (b) shall refer to a person who has the right to work done and who bears the responsibility and risk associated with carrying out the work.

5. Notwithstanding the previous provisions of this Article, remuneration received on account of employment carried on board a ship, boat, aircraft, road or rail vehicle operating in international transport may be taxed in the Contracting State of which the undertaking operating the ship, boat, aircraft, road or railway vehicle is resident.

Tantiems

Tantiéms and other similar payments received by a resident of a Contracting State as a member of the Management Board or any other similar body of a company resident of the other Contracting State may be taxed in that other State.

Artists and athletes

1. Revenue received by a resident of a Contracting State as a public performer, such as a theatre, film, radio or television artist or musician, or as an athlete from such personally performed activities in the other Contracting State, may be taxed in that other State regardless of the provisions of Articles 14 and 15 of this Treaty.

2. Where the income from activities personally carried out by an artist or athlete does not originate from artists or athletes themselves but from other persons, such income may be taxed in the Contracting State in which the activities of an artist or athlete are carried out, regardless of the provisions of Articles 7, 14 and 15 of this Treaty.

3. Notwithstanding the provisions of paragraphs 1 and 2, the revenue referred to in this Article shall be exempt from taxation in the Contracting State in which the activities of an artist or athlete are carried out where such activities are mainly financed by public funds of the other State or are carried out under a cultural cooperation agreement between the Contracting States.

Pension

1. Pensions and other similar salaries paid to a resident of a Contracting State on account of former employment and any annuity paid to such resident shall be subject to taxation in that State only, subject to the provisions of Article 19 (2) of this Treaty.

2. The term "annuity" shall refer to a specified amount paid to a natural person repeatedly within the specified periods of his or her life or during a certain or identifiable period of time on the basis of an obligation to make payments by way of compensation for the corresponding and full remuneration in cash or money.

3. Notwithstanding the provisions of paragraph 1 of this Article, pensions and other similar salaries and any annuity paid under a national pension scheme as part of a social security scheme of a Contracting State, its lower administrative department or local authority shall be subject to taxation only in that State.

Public functions

1. (a) Rewards other than pensions paid by one Contracting State or by a lower administrative department or local authority of that State to a natural person for services rendered to that State or branch or office shall be subject to taxation only in that State.

(b) Such remuneration shall, however, be subject to taxation only in the second Contracting State where the services are demonstrated in that State and the natural person resident in that State:

(i) is a national of that State; or

(ii) it did not become a resident of that State solely for the purpose of proving these services.

2. (a) Any pension paid by one Contracting State or a lower administrative department or local authority of that State or paid from the funds which they have set up shall be subject to taxation only in that State to a natural person for the services shown to that State or department or office.

(b) However, such pensions shall be subject to taxation only in the second Contracting State if the natural person is resident and a national of that State.

3. The provisions of Articles 15, 16 and 18 of this Treaty shall apply to the remuneration and pensions of services shown in connection with an industrial or commercial activity carried out by a Contracting State or a lower administrative department or local authority of that State.

Students

Payments received by a student or apprentice who, or immediately before his or her arrival in a Contracting State, was resident in the other Contracting State and who is resident in the former State for the sole purpose of his or her education or training, shall not be subject to taxation in that State for the purpose of paying the cost of his or her nutrition, education or training, provided that such payments originate from sources outside that State.

Other revenue

Citation	Communication from the Ministry of Foreign Affairs No. 103 / 1999 Coll., on the Agreement between the Government of the Czech Republic and the Government of Ukraine on the avoidance of double taxation and the prevention of tax evasion in the field of income and property taxes
Regulation Type	-
Author	-
Collection	Code of Laws

Date of Promulgation	03.06.1999
Effective from	20.04.1999
Effective until	-
Status	Valid

Communication from the Ministry of Foreign Affairs on the Treaty between the Government of the Czech Republic and the Government of Ukraine on the avoidance of double taxation and the prevention of tax evasion in the field of income and property taxes

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