Communication from the Ministry of Foreign Affairs No. 18 / 1999 Coll.
Communication from the Ministry of Foreign Affairs on the Treaty between the Czech Republic and Mongolia on the avoidance of double taxation and the prevention of tax evasion in the field of income and property taxes
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International Treaty
Effective from 22.06.1998
Text versions:
29.01.1999
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18
COMMUNICATION
Ministry of Foreign Affairs
The Ministry of Foreign Affairs announces that on 27 February 1997 a Treaty was signed in Prague between the Czech Republic and Mongolia 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 on 22 June 1998 on the basis of Article 29 (2) thereof and its provisions shall be implemented in accordance with paragraph 2 (a) and (b). According to paragraph 3 of that Article, on the date on which this Treaty is implemented, the following shall cease to be implemented in relations between the Czech Republic and Mongolia:
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 translation of the Treaty is announced simultaneously. The English version of the Treaty can be consulted at the Ministry of Foreign Affairs and the Ministry of Finance.
TREATY
between the Czech Republic and Mongolia on the avoidance of double taxation and tax evasion in the field of income and property taxes
Czech Republic and Mongolia,
Desiring to conclude a contract to avoid double taxation and prevent tax evasion in the field of income and property taxes,
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 current taxes covered by this contract are:
(a) in the case of Mongolia:
(i) income tax on natural persons,
(ii) company income tax,
(hereinafter referred to as the Mongolian 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. This Treaty shall also apply to any tax of the same or, in principle, similar kind which will be imposed upon signature of the Treaty in addition to or in place of the current taxes referred to in paragraph 3. The competent authorities of the Contracting States shall communicate to each other any substantial changes to be made to their respective tax laws within a reasonable period of time following such changes.
General definitions
1. For the purposes of this Treaty, unless the link requires a different interpretation:
(a) the terms "one Contracting State" and "the other Contracting State" indicate, as appropriate, the Czech Republic or Mongolia;
(b) the term "Mongolia," when used in geographical importance, indicates the territory of Mongolia and any area in which the Mongolia Tax Act applies, where Mongolia exercises, in accordance with international law, sovereign rights to exploit its natural resources;
(c) 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;
(d) the term "person" includes a natural person, a company and any other association of persons;
(e) the term "company" refers to any legal person or rightholder considered to be a legal person for taxation purposes;
(f) 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;
(g) 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;
(h) the term "international transport" refers to any transport by ship, aircraft, road or rail vehicle operated by an undertaking which has its place of effective management in one Contracting State, except where a ship, aircraft, road or railway vehicle is operated only between points in the other Contracting State;
(i) the term "competent authority" shall mean:
(i) in the case of Mongolia, the Minister of Finance or his authorised representative,
(ii) in the case of the Czech Republic, the Minister of Finance or his authorised representative.
2. With regard to the application of the Treaty by a Contracting State, any term not defined therein shall have such meaning as it may have under the legislation of that Contracting 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 establishment 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, 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 State in which he has a permanent residence; if it has a permanent residence in both States, it is assumed to be resident in the State to which it has closer personal and economic relations (centre of life interests);
(b) if it cannot be determined in which State the person has a centre of his life interests, or if he does not have a permanent residence in any State, he shall be presumed to be resident in the State in which he normally resides;
(c) where that person normally resides in both States or in none of them, he shall be presumed to be resident in the State of which he is a national;
(d) where that person is a national of both States or none 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, he shall be presumed to be resident in the State where the place of 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; and
(f) mine, oil or gas site, quarry or any other place where natural resources are extracted.
3. the term "permanent establishment" also covers:
(a) construction site or construction, installation or installation project or supervision associated with it, but only if such construction, project or supervision lasts more than 12 months;
(b) the provision of services, including consultancy or management services, by an undertaking of one contracting State through staff or other personnel hired by the undertaking for that purpose, but only where activities of that nature persist within the territory of the other contracting State for one or more periods exceeding a total of 6 months 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, notwithstanding the provisions of paragraphs 1 and 2, a person - other than an independent representative to whom paragraph 7 applies - acts in one Contracting State on the behalf of an undertaking of the other Contracting State, that undertaking shall be deemed to have a permanent establishment in the former State in respect of all activities undertaken by that person for the undertaking, where such a person:
(a) it has and usually uses an authorisation in that State to conclude contracts on behalf of an undertaking where the activities of such a person are not limited to the activities referred to in paragraph 4 which, if carried out through a permanent place of business, would not constitute a permanent establishment from that permanent place of business in accordance with the provisions of this paragraph; or
(b) it does not have such authorisation, but normally maintains in that State a supply of goods from which it regularly supplies the goods on behalf of the undertaking.
6. Notwithstanding the previous provisions of this Article, an insurance undertaking of one Contracting State, with the exception of reinsurance premiums, shall be presumed to have a permanent establishment in the other Contracting State where it collects insurance premiums in the territory of that other State or insure risks arising there through a person other than an independent representative to whom paragraph 7 applies.
7. An undertaking of one Contracting State shall not be considered to have a permanent establishment in the other Contracting State only because it carries out its activities in that other State through a broker, a general agent or any other independent agent, where such persons act in the course of their proper activities. However, where the activities of such a representative are wholly or almost entirely devoted to the interests of that undertaking, that representative shall not be considered as independent within the meaning of this paragraph.
8. 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 to be allocated to mining mineral deposits, springs and other natural resources apply; ships, aircraft, road and railway vehicles shall not be regarded as immovable property.
3. Paragraph 1 shall apply to revenue received from direct use, hire or any other use of immovable property.
(4) Paragraphs 1 and 3 shall also apply to income from the company's immovable property and to income from immovable property used to pursue 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 its activities in the other Contracting State through a permanent establishment situated there, it shall be attributed, subject to the provisions of paragraph 3, in each Contracting State of that permanent establishment, to profits which could have been achieved if it had been engaged in the same or similar activities as a separate undertaking 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 purposes of the business of a 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.
4. Where, in a Contracting State, 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 shall preclude that Contracting State from determining the profits to be taxed by this normal division; 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 from the operation of ships, aircraft, road or rail vehicles in international transport shall be subject to taxation only in the Contracting State in which the place of effective management of the undertaking is situated.
2. Where the actual management of a shipping undertaking is on board a ship, it shall be deemed to be located in the Contracting State in which the ship's home port is situated or, failing that, in the Contracting State of residence of the ship's operator.
3. Paragraph 1 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, resident in the other 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 other Contracting State, the tax thus imposed shall not exceed 10 per cent of the gross amount of dividends.
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 that case, the provisions of Article 7 or Article 14 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 Contracting 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 in which dividends are paid actually relates to a permanent establishment or a permanent base located in that other Contracting State, nor may it subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or earnings retained in whole or in part of the profits or income generated 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 law 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 10% of the gross amount of interest.
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 unsecured by a mortgage on immovable property or having or not having the right to participate in the debtor's profits, and in particular, income from government securities and income from bonds or bonds, including premiums and winnings related to such securities, bonds or bonds. Penalties imposed for late payment shall not be considered as interest for the purposes of this Article.
5. The provisions of paragraphs 1 and 2 shall not apply where the beneficial owner of interest resident in one of the Contracting States is engaged in a source, industrial or commercial activity, through a permanent establishment situated there, or in an independent profession in that other State, from a permanent base situated there, and where the claim on which interest is paid is actually linked to that permanent establishment or permanent base. In that case, the provisions of Article 7 or Article 14 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.
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 television or radio broadcasting, any patent, trademark, design or model, plan, secret formula or production process or any industrial, commercial or scientific establishment, or for information relating to experience acquired in the field of industrial, commercial or scientific.
4. The provisions of paragraphs 1 and 2 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 in a permanent establishment located there in that other Contracting State, or where the right or property giving rise to royalties is actually linked to that permanent establishment or permanent establishment. In that case, the provisions of Article 7 or Article 14 shall apply depending on the case.
5. 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.
6. 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.
Profit from disposal
(1) Profit received by a resident of a Contracting State from the disposal of immovable property referred to in Article 6, located in the other Contracting State, may be taxed in that other State.
(2) Profit from the disposal of movable property which is part of an operating property of a permanent establishment which is owned by an undertaking of one Contracting State in the other Contracting State, or of movable property belonging to a permanent base which is owned by a resident of one 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.
3. Profit from the disposal of ships, aircraft, road or railway vehicles operating in international transport or movable property which are used for the operation of such ships, aircraft, road or railway vehicles shall be subject to taxation only in the Contracting State in which the place of effective management of the undertaking is situated.
(4) Profit from the disposal of any assets other than those referred to in paragraphs 1, 2 and 3 shall be subject to taxation only in the Contracting State of residence of which the extraneous 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 Contracting State, except in the following cases where such revenue may also be taxed in the other Contracting 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 Contracting State; or
(b) if his stay in the other Contracting State for one or more periods exceeds 183 days in total in any 12-month period beginning or ending in the relevant tax year; in that case, only that part of the income resulting from his activities carried out in that other Contracting State may be taxed in that other Contracting 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 to taxation in that Contracting State only, subject to the provisions of Articles 16, 18, 19, 20 and 21, if the employment is not carried out in the other Contracting State. Where there is employment there, the remuneration received may be taxed in that other Contracting State.
(2) The remuneration received by a resident of a Contracting State on the grounds of employment in the other State shall be subject, notwithstanding the provisions of paragraph 1, to taxation only in the former State where all the following conditions are met:
(a) the beneficiary shall be employed in the other Contracting State for one or more periods not exceeding 183 days in total in any 12-month period beginning or ending in the relevant tax year; and
(b) the 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 the paragraphs of this Article, remuneration received on account of employment carried out on board a ship or aircraft or on a road or railway vehicle operating in international transport may be taxed in the Contracting State in which the place of effective management of the undertaking is situated.
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 Contracting State, irrespective of the provisions of Articles 14 and 15.
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, that income may be taxed, irrespective of the provisions of Articles 7, 14 and 15, in the Contracting State in which the activities of an artist or athlete are carried out.
3. Notwithstanding the provisions of paragraphs 1 and 2, revenue received from activities carried out by an artist or an athlete in one Contracting State shall be subject to taxation only in the other Contracting State if the visit of the former State is mainly financed from public funds of the second Contracting State or from lower administrative departments or local authorities of that other State.
Pension
1. Pensions and other similar salaries paid to a resident of a Contracting State on account of former employment shall be subject to taxation in that State only, subject to the provisions of Article 19 (2).
2. Notwithstanding the provisions of paragraph 1, pensions and other similar salaries paid by a Contracting State or a lower administrative department or local authority of that State on the basis of a public scheme which is part of the social security scheme of that Contracting State shall be subject to taxation only in that Contracting 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 to a lower administrative department or local authority 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 a 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 services demonstrated to that State or to a lower administrative department or local authority.
(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 shall apply to the remuneration and pensions of services demonstrated 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.
Teachers and researchers
1. A natural person who is resident in the former Contracting State, or immediately prior to his or her arrival in one Contracting State, and who resides in the former Contracting State for the primary purpose of teaching, lecturing or carrying out research at the university, university, educational or scientific research institution officially recognised by the Government of the former Contracting State shall be exempt from taxation in the former Contracting State for a period of two years from the date of his or her first arrival in the former Contracting State as regards remuneration for such teaching, lecture or research.
2. The provisions of this Article shall apply to research revenue only if such research is carried out by a natural person in the public interest and not primarily for the benefit of a private person or persons.
Students and apprentices
1. A student or apprentice who is, or immediately before his or her arrival in a Contracting State, resident in a second State and who resides in the former State only for the purpose of his or her education or training shall be exempt from taxation in that former State in respect of the following payments or receipts received or received for the purpose of paying the cost of his or her nutrition, education or training:
(a) payments received from sources outside that Contracting State; and
(b) aid, grants or remuneration granted by the Government of a Contracting State or by a scientific, educational, cultural or non-profit organisation.
2. The student or apprentice referred to in paragraph 1 shall also have the right, in respect of the remuneration of the employment or profession not covered by paragraph 1, during such training or training, to the same tax exemptions, concessions or reductions as are due to the residents of the State in which he resides.
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Regulation Information
| Citation | Communication from the Ministry of Foreign Affairs No. 18 / 1999 Coll., on the Agreement between the Czech Republic and Mongolia on the avoidance of double taxation and the prevention of tax evasion in the field of income and property taxes |
|---|---|
| Regulation Type | International Treaty |
| Author | - |
| Collection | Code of Laws |
| Date of Promulgation | 29.01.1999 |
|---|---|
| Effective from | 22.06.1998 |
| Effective until | - |
| Status | Valid |
The regulation text is for informational purposes only.
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