Communication from the Ministry of Foreign Affairs No. 31 / 1994 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 Poland on the avoidance of double taxation in the field of income and property taxes
Valid
Effective from 20.12.1993
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31
COMMUNICATION
Ministry of Foreign Affairs
The Ministry of Foreign Affairs announces that on 24 June 1993 a Treaty was signed in Warsaw between the Government of the Czech Republic and the Government of the Republic of Poland to avoid double taxation in the field of income and property taxes.
The Parliament of the Czech Republic gave its assent to the Treaty and the President of the Republic ratified it.
The Treaty entered into force on 20 December 1993 pursuant to Article 29 (2) thereof. The Treaty between the Czechoslovak Republic and the Republic of Poland on the avoidance of double taxation in the field of direct taxation of the State of 23 April 1925, published under No 255 / 1925 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
Government of the Czech Republic
and
Government of the Republic of Poland
on the avoidance of double taxation in the field of income and property taxes
The Government of the Czech Republic and the Government of the Republic of Poland, wishing to promote economic relations by removing fiscal barriers and deciding to conclude a Double Taxation Treaty in the field of income and property taxes, have agreed as follows:
PERSONS CONCERNING THE TREATY
This contract shall apply to persons resident in one or both Contracting States (residents).
TAXES TO WHICH THE TREATY IS RELATING
1. This Agreement shall apply to income and property taxes imposed 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 some or all of the income or assets, including taxes on the proceeds from the disposal of movable or immovable property, taxes on the amount of 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:
(a) in Poland:
(i) income tax on natural persons (dochodowy from persons fizycznych);
(ii) corporate tax (dochodowy dochodowy from prawnych persons);
(iii) agricultural tax (roll tax);
(hereinafter referred to as "Polish 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. This Treaty shall also apply to taxes of the same or similar kind to be imposed by one of the Contracting States following the signature of this Treaty in addition to or instead of the current taxes. 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 "Poland," when used in the geographical sense, refers to the territory of the Republic of Poland, including any area outside its territorial waters over which Poland may exercise its sovereign rights, in accordance with the law of Poland and in accordance with international law, relating to the seabed, its subsoil and its natural resources;
(b) the terms "one Contracting State" and "the other Contracting State" refer to the Czech Republic or Poland as appropriate;
(c) the term "person" includes a natural person, company and any other association of persons;
(d) the term "company" refers to a legal person or rightholder treated as a legal person for taxation purposes;
(e) the terms "undertaking of one Contracting State" and "undertaking of the other Contracting State" refer to an undertaking operated by a resident of one Contracting State or an undertaking operated by a resident of the other Contracting State;
(f) 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 law in force in a Contracting State;
(g) the term "international transport" shall mean any transport carried out by a ship, aircraft, railway or road vehicle operated by an undertaking whose place of effective management is situated in one Contracting State, unless such transport is carried out only between points in the other Contracting State;
(h) the term "competent authority" shall mean:
(i) in the case of the Czech Republic, the Minister of Finance of the Czech Republic or his authorised representative;
(ii) in the case of Poland, the Minister for Finance of Poland or his authorised representative.
2. Any term which is not otherwise defined shall have a Contracting State's meaning for the application of this Treaty under the law of that State which regulates the taxes covered by this Treaty, 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 a person who is subject to taxation in that Contracting State solely for reasons of income from resources in that State or property situated in that State.
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 Contracting State in which he has a permanent residence; if it has a permanent residence in both Contracting States, it is assumed to be resident in the Contracting State to which it has closer personal and economic relations (the Centre of Life Interests);
(b) if it cannot be determined in which Contracting State the person has a centre of his life interests or if he does not have a permanent residence in any Contracting State, he shall be presumed to be resident in the Contracting State in which he 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 citizen;
(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 paragraph 1, he shall be presumed to be resident in the State in which the place of his actual management is situated. In case of doubt, the competent authorities of the Contracting States shall adjust the matter by mutual agreement.
STANDING OPERATIONS
1. For the purposes of this Treaty, the term "permanent establishment 'shall refer to a permanent establishment for the business in which the undertaking carries out its activities 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 other place where natural resources are extracted.
3. The construction site or construction or installation or installation project shall be considered as a permanent establishment if it lasts more than 12 months from the date on which the work actually began.
4. Notwithstanding the previous provisions of this Article, the term "permanent establishment 'shall not include:
(a) an establishment which is used only for the storage, display or supply of goods belonging to the undertaking;
(b) the supply of goods belonging to an undertaking which is maintained only for storage, display or delivery;
(c) a stock of goods belonging to an undertaking which is maintained only for the purpose of processing by another undertaking;
(d) permanent business equipment which is maintained only for the purpose of purchasing goods or collecting information for the undertaking;
(e) permanent business equipment which is maintained only for the purpose of advertising, the provision of information, scientific research or similar activities which have a preparatory or ancillary character for the undertaking;
(f) a permanent establishment for business which shall be maintained only for the exercise of any combination of the activities referred to in subparagraphs (a) - (e) where the total activity of the permanent establishment resulting from that concentration is of a preparatory or ancillary nature.
5. Where, notwithstanding 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 at its disposal and normally uses the power of attorney enabling it 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 establishment, would not constitute the existence of a permanent establishment in accordance with the provisions of this paragraph.
6. 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.
7. The fact that a company that is resident in one Contracting State controls the company or is controlled by a company that is resident in the other Contracting State or that carries out its activities there (and through a permanent establishment or otherwise) does not in itself make it 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 and forestry income) located in the other Contracting State may be taxed in that other State.
2. The term "immovable property" shall have the meaning of 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, buildings, the right to consume immovable property and the right to variable or fixed salaries for mining or admission to mining mineral deposits, springs and other natural resources apply; ships, boats and aircraft shall not be considered property.
3. Paragraph 1 shall apply to income from direct use, rental or any other use of immovable property.
(4) Paragraphs 1 and 3 shall also apply to income from the property of the undertaking and to income from immovable property used for the exercise of the profession.
PROFIT OF UNDERTAKINGS
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. Where an undertaking carries out its activities in this way, the profits of the undertaking may be taxed in that other State, but only to the extent that they can be attributed to that permanent establishment.
2. Where an undertaking of a Contracting State carries out 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 State, to profits which 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 is permitted to deduct the costs incurred by an undertaking for the objectives pursued by that permanent establishment, including management expenses and general administrative expenses thus incurred, whether they arise in the State in which that 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, the provisions of paragraph 2 shall not preclude that Contracting State from determining the profits to be taxed by this normal distribution; However, the method of distribution of profits 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 attributed to a permanent establishment shall be determined in the same way each year, unless there are sufficient grounds for otherwise.
7. Where profits include revenue which is dealt with separately in other Articles of this Treaty, the provisions of those Articles shall not be affected by the provisions of this Article.
INTERNATIONAL TRANSPORT
1. Profit from the operation of ships, boats or aircraft or railway and road vehicles in international transport shall be subject to taxation only in the Contracting State in which the head office of the undertaking is situated.
2. Profit from the operation of inland waterway vessels in conjunction with international transport is subject to taxation only in the Contracting State in which the head office of the undertaking's actual management is located.
3. Where the actual management of a maritime or inland waterway undertaking is on board a ship or a boat, it shall be deemed to be located in the Contracting State in which the home port of that ship or boat is situated or, in the absence of such a home port, in the Contracting State in which the operator of the ship or boat is resident.
4. Paragraph 1 shall also apply to profits arising from participation in a pool, joint operation or an international operational organisation.
ASSOCIATED 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 are directly or indirectly involved 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 agreed 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 Contracting State.
2. However, such dividends may also be taxed in the Contracting State in which the company which pays them is resident under the legislation of that State, but where the beneficiary is the beneficial owner of dividends, the tax shall not exceed:
(a) 5% of the gross amount of dividends where the beneficiary is a company (other than a personal company) which directly owns at least 20% of the assets of the company paying dividends;
(b) 10% of the gross amount of dividends in all other cases.
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 rights to companies which, under the tax legislation of the State in which the company which differentiates profits is resident, are equivalent to income from shares.
4. The provisions of paragraphs 1 and 2 shall not apply where the beneficial owner of dividends resident in one Contracting State is engaged in an industrial or commercial activity in the second Contracting State in which the dividend company is resident through a permanent establishment situated there or is engaged in an independent occupation in that other State through a permanent base situated there, and where the participation for which dividends are paid actually relates to that permanent establishment or to that permanent establishment. 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 belongs to a permanent establishment or a permanent base located in that other State, or subject the company's undistributed profits to the tax on undistributed profits, even if the dividends paid or retained earnings are wholly or partly derived from profits or income obtained in that other State.
INTEREST
1. Interest having a source in one Contracting State which is received by a resident of the other Contracting State may be taxed in that State.
2. However, the interest referred to in paragraph 1 of this Article may also be taxed in the Contracting State in which they have a source and under the legislation of that State, but where the beneficiary is the beneficial owner of the interest, the tax thus imposed shall not exceed 10% of the gross amount of interest.
3. Notwithstanding the provisions of paragraph 2, interest, the source of which is in one Contracting State and which is received by the Government of the other Contracting State, including its local authorities, the Central Bank or any financial institution controlled by that Government, or interest resulting from loans guaranteed by that Government, shall be exempt from tax in the former Contracting State.
4. The term "interest" used in this Article shall refer to income from claims of any kind secured or not secured by a lien on immovable property or having or not having the right to participate in the debtor's profit, and in particular, income from government securities and income from bonds or bonds, including premiums and rewards associated with such securities, bonds or bonds. Penalties for 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 through an independent profession located there, and where the claim on which the interest is paid actually relates to that permanent establishment or to that permanent establishment. In that case, the provisions of Article 7 or Article 14 shall apply, depending on the case.
6. Interest is assumed to have a source in one Contracting State, if the payer is the latter himself, its lower administrative department, the local office or resident of that State. However, if the person paying interest, whether resident in a Contracting State or not, has a permanent establishment or a permanent base in the Contracting State in respect of which the debt on which the interest is paid has been incurred and such interest is chargeable to such a permanent establishment or permanent base, the State in which the permanent establishment or permanent base is located shall be deemed to be the source of such interest.
7. Where the amount of interest relating to the claim on which it is paid exceeds the amount which the payer would have agreed with the beneficial owner if it were not for such a relationship, the provisions of this Article shall apply only to that latter amount. In this case, the amount of the salary exceeding it shall be taxed under the legislation of each Contracting State, taking into account the other provisions of this Treaty.
LICENCES
1. Licensing fees, having a source in one Contracting State, paid by a resident of the other Contracting State, may be taxed in that other State.
2. However, the licence fees referred to in paragraph 1 may also be taxed in the Contracting State in which their source is located and in accordance with the legislation of that State, but where the recipient is the beneficial owner of the licence fees, the amount of the tax thus determined shall not exceed 5% of the gross amount of the licence fee.
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 copyright for the work of literary, artistic or scientific including cinematographic films and films or recordings for television or radio broadcasting, patent, trade mark, design or model, plan, secret formula or production process, or for use or for the use of industrial, commercial or scientific equipment, 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 royalties resident in one Contracting State is engaged in a source, industrial or commercial activity through a permanent establishment situated there, or an independent profession through a permanent base situated there, and where the right or property giving rise to royalties is actually linked to that permanent establishment or permanent base. In this 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 a Contracting State if the payer is the State itself, its administrative department, local authority 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 charged to a permanent establishment or permanent base, it is assumed that such licence fees have a source in the Contracting State in which the permanent establishment or permanent base is located.
6. Where the amount of the licence fees relating to the use, right or information for which they are paid exceeds the amount which the payer would have agreed with the beneficial owner if it were not for such relationships, the provisions of this Article shall apply only to that last amount. In this case, the amount of the salary exceeding it shall be taxed under the legislation of each Contracting State, taking into account the other provisions of this Treaty.
OWN FUNDS PROFIT
(1) Profit accruing to 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 the assets of a permanent establishment held by an undertaking of a Contracting State in the other Contracting State, or of movable property belonging to a permanent base which a resident of one Contracting State has in the other Contracting State to pursue an independent occupation, including such profits obtained from the disposal of such permanent establishment (on its own or together with the whole undertaking) or such permanent base may be taxed in that other State.
3. Profit from the disposal of ships, boats or aircraft operating in international transport or movable property serving the operation of such ships, boats or aircraft shall be subject to taxation only in the Contracting State in which the head office of the undertaking is situated.
(4) Profit from the disposal of assets other than those referred to in paragraphs 1, 2 and 3 shall be subject to taxation only in the Contracting State in which the transferee is resident.
_
1. Revenue received by a resident of a Contracting State from a professional or other independent activity of a similar nature shall be subject to taxation only in that State, provided that the beneficiary does not normally have a permanent basis in the other Contracting State to carry out his activities. If such a permanent base is available, income may be taxed in the other Contracting State, but only to the extent that it can be attributed to that permanent base.
2. The term "free profession" includes the particularly independent activities of scientific, literary, artistic, educational or teaching and the separate 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, 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 for them 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 where all the following conditions are met:
(a) the consignee shall stay in the other State for one or more periods which shall not exceed 183 days in total in any 12-month period; and
(b) the remuneration is paid by the employer or by an employer who is not resident in the other State; and
(c) the remuneration shall not be borne by a permanent establishment or 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 out on board a ship or aircraft in international transport or on board a boat in inland waterway transport in conjunction with international transport may be taxed in the Contracting State in which the head office of the undertaking is situated.
TANTIES
Tantiéms and other similar remuneration received by a resident of one Contracting State as a member of the Management Board or another similar body of a company resident in the other Contracting State may be taxed in that other State.
Artists and SPORTS
1. Revenue received by a resident of a Contracting State as a public performer, such as a theatre, film, radio or television artist, or a 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.
2. Where the income from activities personally carried out by an artist or an athlete does not result from such an artist or athlete alone but from another person, that income may be taxed, irrespective of the provisions of Articles 7, 14 and 15, in the Contracting State in which the artist or athlete carries out his activity.
3. The revenue referred to in this Article shall, notwithstanding the provisions of paragraphs 1 and 2, be exempt from taxation in the Contracting State in which the artist or athlete carries out his activity, provided that such activity is paid for in a substantial part from the public funds of that State or of the other State, or that activity is carried out under a cultural agreement or arrangement between the Contracting States.
PENZE
Pensions and other similar salaries paid on account of former employment of a resident of a Contracting State shall be subject to taxation, subject to the provisions of paragraph 2 of Article 19, only in the Contracting State in which the recipient of the pension is resident.
PUBLIC FUNCTIONS
1. (a) Rewards, other than pensions, paid by one Contracting State or administrative department or local authority of that State to a natural person for services rendered to that State or administrative department or local authority shall be subject to taxation only in that State.
(b) However, such remuneration shall 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 State citizen of that State; or
(ii) has not become resident in that State solely because of the provision of such services.
2. (a) Penalties paid either directly or from funds established by a Contracting State, an administrative department or a local authority of that State, to a natural person for services rendered to that State, an administrative department or a local authority shall be subject to taxation only in that State.
(b) Such pensions shall, however, be subject to taxation only in the second Contracting State if the natural person is resident and a national citizen 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, an administrative department or a local authority of that State.
STUDENTI
1. Salaries received by a student or apprentice who is, or was, resident in a Contracting State immediately prior to his or her arrival in the other Contracting State and who resides in the former State for the sole purpose of study or training shall not be taxed in that State for the cost of nutrition, study or training, provided that such salaries are paid to him from sources outside that State.
2. A student at a university or other higher education institution in one Contracting State, or an apprentice who resides in the other Contracting State for one or more periods not exceeding 183 days within any 12-month period and who is, or immediately before such visit, resident in the former State, shall not be taxed in the other Contracting State on the remuneration for services provided in that other State, provided that such services are carried out in connection with his studies or training and that such remuneration constitutes the income necessary for his necessary nutrition.
PROFESSIONAL AND RESEARCH WORKERS
1. A natural person who visits one Contracting State for the purpose of teaching or carrying out research at a university, university or other recognised educational institution in that Contracting State and who is or was immediately prior to such a visit resident of the other Contracting State shall be exempt from taxation in the former Contracting State from remuneration for such teaching or research for a period not exceeding two years from the date of the first visit for that purpose.
2. Paragraph 1 of this Article shall not apply to research revenue where such research is carried out not for the public interest but primarily for the private benefit of a person or persons.
OTHER REVENUE
1. The income of a person resident in a Contracting State and having a source anywhere not covered by the preceding Articles of this Treaty shall be subject to taxation only in that State.
2. The provisions of paragraph 1 shall not apply to revenue, other than income from immovable property as defined in paragraph 2 of Article 6, where the recipient of such revenue resident in a Contracting State carries out industrial or commercial activities in the other Contracting State through a permanent establishment situated there, or carries out an independent occupation in that other State from a permanent base situated there, and where the right or property for which revenue is paid is actually linked to such permanent establishment or permanent base. In that case, the provisions of Article 7 or Article 14 shall apply depending on the case.
_
1. Property represented by the immovable property referred to in Article 6 which is owned by a resident of one Contracting State and which is located in the other Contracting State may be taxed in that other State.
2. Property represented by movable property which is part of the operating property of a permanent establishment held by an undertaking of one Contracting State in the other Contracting State, or movable property belonging to a permanent base held by a resident of one Contracting State in the other Contracting State for the pursuit of an independent occupation, may be taxed in that other State.
3. Property represented by ships, boats, aircraft or railway and road vehicles used in international transport and movable property used to operate such ships, boats, aircraft or railway and road vehicles shall be subject to taxation only in the Contracting State in which the actual management of the undertaking is located.
4. All other assets of a resident of a Contracting State shall be subject to taxation only in that State.
TERMINATION OF DOUGH REVENUE
1. In the case of a resident of Poland, double taxation will be avoided as follows:
(a) Where a resident of Poland receives income or own property which, in accordance with the provisions of this Treaty, may be taxed in the Czech Republic, Poland shall, subject to subparagraph (b) and (3), exempt such income or property from taxation. Poland may, however, apply the rate of tax which would have been applied in calculating the amount of tax on other income or on the property of such resident if the revenue excluded had not been so excluded;
(b) If a resident of Poland receives income which may be taxed in the Czech Republic in accordance with the provisions of Articles 10, 11 and 12, Poland shall allow the income tax of that resident to be reduced by an amount equal to that paid in the Czech Republic. However, the amount by which the tax is to be reduced shall not exceed that part of the tax calculated before its reduction, which is proportional to the income generated by the Czech Republic.
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Regulation Information
| Citation | Communication from the Ministry of Foreign Affairs No. 31 / 1994 Coll., on the Agreement between the Government of the Czech Republic and the Government of the Republic of Poland on the avoidance of double taxation in the field of income and property taxes |
|---|---|
| Regulation Type | - |
| Author | - |
| Collection | Code of Laws |
| Date of Promulgation | 15.02.1994 |
|---|---|
| Effective from | 20.12.1993 |
| Effective until | - |
| Status | Valid |
The regulation text is for informational purposes only.
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