Communication from the Ministry of Foreign Affairs No 301 / 1999 Coll.
Communication from the Ministry of Foreign Affairs on the Treaty between the Government of the Czech Republic and the Government of the Republic of India 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 27.09.1999
Text versions:
09.12.1999
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301
COMMUNICATION
Ministry of Foreign Affairs
The Ministry of Foreign Affairs states that on 1 October 1998 a Treaty was signed in Prague between the Government of the Czech Republic and the Government of the Republic of India 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 27 September 1999 pursuant to Article 30 (2) thereof. According to paragraph 4 of the same Article, the date on which this Treaty will be implemented will cease to be implemented in relations between the Czech Republic and the Republic of India between the Government of the Czechoslovak Socialist Republic and the Government of India on the avoidance of double taxation and avoidance of tax evasion in the field of income tax, signed in New Delhi on 27 January 1986, published under No 77 / 1987 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 the Republic of India on the avoidance of double taxation and tax evasion in the field of income and property taxes
the Government of the Czech Republic and the Government of the Republic of India,
Desiring to conclude a contract to avoid double taxation and prevent tax evasion in the field of income and property taxes in order to promote economic cooperation between the two countries,
agree as follows:
Persons to whom the Treaty applies
This Agreement shall apply to persons resident in one or both Contracting States.
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 to which the Treaty applies are in particular:
(a) in India:
(i) income tax, including any premium; and
(ii) tax on total assets;
(hereinafter referred to as the "Indian tax ');
(b) in 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 Treaty shall also apply to any tax of the same or, in principle, similar kind which will be imposed after the 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 significant 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 "India" refers to the territory of India and includes the territorial sea and the airspace above it, as well as any other maritime zone where India exercises sovereign rights, other rights and jurisdiction, under the law of India and in accordance with international law, including the United Nations Convention on the Law of the Sea;
(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 term "person" shall include a natural person, a company, an association of persons and any other rightholder regarded as a tax entity under the applicable tax laws in the relevant Contracting State;
(d) the term "company" refers to any legal person or rightholder regarded as a legal person for taxation purposes;
(e) 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;
(f) the term "international transport" means any transport by ship or aircraft operated by an undertaking resident in one Contracting State, except where the ship or aircraft is operated only between points in the other Contracting State;
(g) the term "competent authority" shall mean:
(i) in India, the Ministry of Finance of the Central Government (State Revenue Department) or its authorised representative;
(ii) in the Czech Republic, the Minister of Finance or his authorised representative;
(h) 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;
(i) the term "tax year" means:
(i) in the case of India, the "previous" year as defined in Section 3 of the Income Tax Act 1961;
(ii) in the case of the Czech Republic, the calendar year;
(j) the term "tax" means, according to context, a Czech tax or an Indian tax but does not include any amount due because of any non-payment or omission in relation to the taxes covered by this Treaty or which constitutes a penalty or fine imposed on such taxes;
(k) the terms "one Contracting State" and "the other Contracting State" indicate, as appropriate, the Czech Republic or the Republic of India.
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 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. If it cannot be determined in which State the place of its actual management is situated, the competent authorities of the Contracting States shall amend this matter by mutual agreement.
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) mine, oil or gas site, quarry or any other place where natural resources are extracted;
(g) the point of sale;
(h) the warehouse as regards the person providing the storage facility to another; and
(i) a farm, plantation or other place where agricultural, forestry, plantation or related activities are carried out.
3. The construction site or construction, installation or installation project or supervision associated with it shall create a permanent establishment only if such construction, project or supervision takes more than six months.
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 shall be maintained only for the purpose of carrying out any other activity which is of a preparatory or ancillary nature for 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 Contracting State in respect of all activities carried out by that person for the undertaking if that person:
(a) it has and usually uses in that State an authorisation which allows it to conclude contracts on behalf of an undertaking where 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 constitute a permanent establishment under the provisions of this paragraph; or
(b) it does not have such authorisation but normally maintains in the former 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 the risks that are present there through a person other than an independent representative to whom paragraph 7 applies.
7. An undertaking shall not be deemed to have a permanent establishment in a Contracting State only because it carries on 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. 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 also 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, boats, aircraft and motor 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 also 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 objectives pursued by the permanent establishment, including management costs and general administrative expenses thus incurred, whether incurred in the State where the permanent establishment is located or elsewhere, in accordance with the provisions and subject to the limitations of the tax laws of that State.
4. A permanent establishment shall not make any profits on the basis that it only purchased goods for the undertaking.
(5) 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.
6. 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.
Transport by ship and air
(1) Profit accruing to an undertaking of a Contracting State from the operation of ships or aircraft in international transport shall be subject to taxation only in that State.
2. Profit accruing to a transport undertaking resident in a Contracting State from the use, maintenance or hire of containers (including trailers and other container equipment) used for the carriage of goods in international transport shall be subject to taxation only in that Contracting State, provided that the containers are not used only in the territory of the other Contracting State.
3. For the purposes of this Article, interest on funds directly related to the operation of ships or aircraft in international transport shall be considered to be profits resulting from the operation of such ships or aircraft and the provisions of Article 11 shall not apply in respect of such interest.
4. 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 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 which are 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 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 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 shall be exempt from taxation in that Contracting State if it is received and actually owned or received in connection with a loan or loan granted or guaranteed:
(a) the government, the lower administrative department or the local authority of the other Contracting State; or
(b) (i) in the case of India, the Reserve Bank of India, the Indian Industrial Financial Corporation, the Indian Industrial Development Bank, the India Export-Import Bank, the National Construction Bank, the India Small Business Development Bank and the India Industrial Credit and Investment Corporation (ICICICI); and
(ii) for the Czech Republic, the Czech National Bank, the Czech Export Bank, the Export Guarantee and Insurance Company and the Consolidated Bank; or
(c) any other institution as may be agreed from time to time between the competent authorities of the Contracting States.
4. The term "interest 'used in this Article shall refer to income from claims of any kind, whether secured or not secured by a mortgage on immovable property and 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 as late payment shall not be considered 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 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 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 a 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 borne by such a permanent establishment or permanent base, such interest shall be assumed to have a source in the Contracting 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 and fees for technical services
1. Licensing fees or fees for technical services 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 or fees for technical services may also be taxed in the Contracting State in which they have a source under the legislation of that State, but where the beneficial owner of royalties or technical services is resident in the other Contracting State, the tax thus imposed shall not exceed 10 per cent of the gross amount of royalties or technical services.
3. (a) The term "licence fees" used in this Article shall refer to payments of any kind received as compensation for use or as the 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, trade mark, 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.
(b) The term "technical service charges" used in this Article shall refer to payments of any kind received as compensation for the demonstration of any management, technical or advisory services, including the provision of services by technical or other staff, but shall not include payments for services referred to in Articles 14 and 15 of this Treaty.
4. The provisions of paragraphs 1 and 2 shall not apply where the beneficial owner of royalties or fees for technical services resident in a Contracting State is engaged in a source, industrial or commercial activity through a permanent establishment situated there or an independent profession from a permanent base located there in that other State, and where the right or property giving rise to royalties or technical services 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. Licensing or technical service charges are assumed to have a source in the Contracting State, if the payer is the latter himself, a lower administrative department, a local authority or a resident of that State. However, where a licence fee or technical service fee payer, whether or not he is a resident of a Contracting State, has a permanent establishment or permanent base in a Contracting State, in conjunction with which a licence fee or technical service fee has been required, and such licence or technical service fees are charged to such a permanent establishment or permanent base, such licence or technical service charges shall be presumed to have a source in the Contracting State in which the permanent establishment or permanent base is located.
6. Where the amount of royalties or fees for technical services relating to the use, right or information for which they are paid exceeds, as a result of special relations 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 which is located in the other Contracting State may also 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 foundations, may also be taxed in that other State.
(3) Profit received by an undertaking in a Contracting State from the disposal of ships or aircraft operating in international transport or movable property which serves to operate such ships or aircraft shall be subject to taxation only in that State.
4. Profit from the disposal of shares in the share capital of a company whose assets remain, directly or indirectly, mainly of immovable property situated in a Contracting State may be taxed in that State.
5. Profit from the disposal of shares in companies other than those referred to in paragraph 4 resident in a Contracting State may be taxed in that State.
6. Profit from the disposal of any property other than those referred to in paragraphs 1, 2, 3, 4 and 5 shall be subject to taxation only in the Contracting State of which the aliener 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 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 State; or
(b) where his stay in the other State for one or more periods is equal to or 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 its activities in that other State may be taxed in that other State.
2. The term "free profession" shall include the particularly independent activities of scientific, literary, artistic, educational or teaching and the independent activities of doctors, lawyers, engineers, architects, surgeons, 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, 19, 20 and 21, to taxation in that State only if the employment is not carried out in the other Contracting State. If there is employment there, such remuneration received from it 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, be subject to taxation only in the former State if all the following conditions are met:
(a) the beneficiary shall stay in the other 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) 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. Notwithstanding the previous provisions of this Article, remuneration received on account of employment carried on board a ship or aircraft operating in international traffic may be taxed by an undertaking of a Contracting State in that State.
4. The term "employer" referred to in paragraph 2 (b) shall include a person who has the right to work done and who bears responsibility and the risk associated with carrying out the work.
Tantiems
Tantiémes and other similar payments received by a resident of one Contracting State as a member of the Board of Directors of a company resident of the other Contracting State may also 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, 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. The provisions of paragraphs 1 and 2 shall not apply to revenue from activities carried out by an artist or athlete in one Contracting State where a visit to that State is predominantly financed by public funds of the other Contracting State or by its lower administrative department or local authority. In such a case, income is subject to taxation only in the Contracting State of residence of the artist or athlete.
Pension
Pensions and other similar salaries paid by a resident of a Contracting State on account of former employment shall be subject to taxation only in that State, subject to the provisions of Article 19 (2).
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 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.
Students and apprentices
1. A student or apprentice who is or has been resident in one Contracting State immediately prior to his or her arrival in the other Contracting State and who resides in that other Contracting State only for the purpose of his or her education or training shall be exempt from taxation in that other State, other than aid, loans and scholarships, also from:
(a) payments made to him by a person residing outside that other State in order to cover the costs of his or her nutrition, education or training; and
(b) remuneration from employment in that other State, not exceeding an amount which is exempt from taxation under the legislation of that other Contracting State for each tax year, provided that such employment is directly related to his studies or is carried out for the purpose of paying the cost of his nutrition.
2. The benefit of this Article shall be granted only for a period of time which is reasonable or normally required to terminate the training or training, but in no case shall any natural person benefit from this Article for more than seven consecutive years from the date of his first arrival in that other Contracting State.
Professors, teachers and researchers
1. A professor or teacher who is or has been resident in one Contracting State immediately prior to his or her arrival in the other Contracting State for the purpose of teaching or participating in research, or both, at a university, university, school or other recognised institution in that other Contracting State shall be exempt from taxation in that other State of any remuneration for such teaching or research for a period not exceeding two years from the date of his or her first arrival in that other State.
2. This Article shall not apply to research revenue where such research is primarily carried out for the private benefit of a person or persons.
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Regulation Information
| Citation | Communication from the Ministry of Foreign Affairs No. 301 / 1999 Coll., on the Agreement between the Government of the Czech Republic and the Government of the Republic of India 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 | 09.12.1999 |
|---|---|
| Effective from | 27.09.1999 |
| Effective until | - |
| Status | Valid |
The regulation text is for informational purposes only.
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