Communication from the Ministry of Foreign Affairs No. 249 / 1993 Coll.
Communication from the Ministry of Foreign Affairs on the negotiation of a Protocol to the Treaty between the Government of the Czechoslovak Socialist Republic and the Government of the Kingdom of Denmark on the avoidance of double taxation in the field of income and property taxes
Valid
Effective from 18.12.1992
249
COMMUNICATION
Ministry of Foreign Affairs
The Ministry of Foreign Affairs states that on 11 September 1992 the Protocol to the Treaty between the Government of the Czechoslovak Socialist Republic and the Government of the Kingdom of Denmark on the avoidance of double taxation in the field of income and property taxes of 5 May 1982 was signed in Prague.
The Federal Assembly of the Czech and Slovak Federal Republic has agreed with the Protocol and has ratified it on behalf of the President of the Czech and Slovak Federal Republic.
The Protocol entered into force on 18 December 1992 pursuant to Article II thereof.
The Czech translation of the Protocol is being announced simultaneously. The English version of the Protocol can be consulted at the Ministry of Foreign Affairs and the Ministry of Finance.
PROTOCOL
to the Treaty between the Government of the Czechoslovak Socialist Republic and the Government of the Kingdom of Denmark on the avoidance of double taxation in the field of income and property taxes
The Government of the Czech and Slovak Federal Republic and the Government of the Kingdom of Denmark, wishing to conclude the Protocol to the Double Taxation Treaty in the field of income and property taxes signed in Prague on 5 May 1982, agreed as follows:
The following shall be added after paragraph 1 (c) of Article 23 of the Treaty:
"(d) Where, pursuant to the Czechoslovak legislation, exemption from taxation or reduction of tax due under the provisions of Article 7 of this Treaty has been granted on the profits of a Danish undertaking from a permanent establishment located in Czechoslovakia, for the purposes of points (a) (i) and (b) of this paragraph, it shall be permitted to reduce the Danish tax on the Czechoslovak tax as if no such exemption or reduction had been granted.
(e) If dividends are paid by a company resident in Czechoslovakia to a person (who is a company) resident in Denmark who owns, directly or indirectly, at least 25% of the capital of the former company, such dividends will be exempt from taxation in Denmark, provided that the company paying dividends deals with the production or sale of goods or services (other than financial services) and that no more than 25% of the company's income comes from interest and the disposal of shares and bonds.
(f) Points (d) and (e) shall apply for the first five years following the entry into force of the Protocol adjusting the original Treaty between Czechoslovakia and Denmark. The competent authorities of the Contracting States shall consult each other to assess any extension of this period. Any such extension shall take effect from such date and under such arrangements and conditions, including conditions for termination, which may be specified and agreed between the Contracting States in notes exchanged by diplomatic means or in any other way appropriate to their constitutional procedures.
1. The Contracting States shall notify each other that the constitutional requirements for the entry into force of this Protocol have been fulfilled.
2. This Protocol, which shall become part of the Treaty, shall enter into force on the date of the later notification referred to in paragraph 1 and its provisions shall apply to taxes for the calendar year immediately following the year in which the Protocol enters into force and for the following calendar years.
In order to prove the signature, which was duly empowered by their governments, they signed this protocol.
Dano in duplicate in Prague on 11 September 1992 in English.
For the Government of the Czech and Slovak Federal Republic:
Jan Klak v. r.
For the Government of the Kingdom of Denmark:
P. Poulsen-Hansen v. r.
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Regulation Information
| Citation | Communication from the Ministry of Foreign Affairs No. 249 / 1993 Coll., on the negotiation of a Protocol to the Treaty between the Government of the Czechoslovak Socialist Republic and the Government of the Kingdom of Denmark on the avoidance of double taxation in the field of income and property taxes |
|---|---|
| Regulation Type | - |
| Author | - |
| Collection | Code of Laws |
| Date of Promulgation | 08.10.1993 |
|---|---|
| Effective from | 18.12.1992 |
| Effective until | - |
| Status | Valid |
The regulation text is for informational purposes only.
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