Decree of the Minister for Foreign Affairs No. 41 / 1988 Coll.

Q: Is Decree of the Minister for Foreign Affairs No. 41 / 1988 Coll. still valid?

Yes, Decree of the Minister for Foreign Affairs No. 41 / 1988 Coll. is still valid and effective.

41

DECLARATION

Minister for Foreign Affairs

of 7 March 1988

on the Treaty between the Government of the Czechoslovak Socialist Republic and the Government of the People's Republic of China on the avoidance of double taxation and the prevention of tax evasion in the field of income taxes

On 11 June 1987, the Treaty was signed in Prague between the Government of the Czechoslovak Socialist Republic and the Government of the People's Republic of China to avoid double taxation and prevent tax evasion in the field of income tax.

The Treaty was approved by the Federal Assembly of the Czechoslovak Socialist Republic and ratified by the President of the Czechoslovak Socialist Republic.

The Treaty entered into force on 23 December 1987 pursuant to Article 28 thereof.

The Czech version of the Treaty is hereby published at the same time.

Minister:

Ing. Chupek v. r.

TREATY

between the Government of the Czechoslovak Socialist Republic and the Government of the People's Republic of China on the avoidance of double taxation and the prevention of tax evasion in the field of income taxes

The Government of the Czechoslovak Socialist Republic and the Government of the People's Republic of China wish to conclude a double taxation agreement and prevent tax evasion in the field of income taxes,

they have agreed as follows:

Persons covered by the contract

This contract applies to persons residing or having their registered office in one or both Contracting States (residents).

Taxes covered by the contract

1. This Treaty shall apply to income taxes levied in favour of the Contracting State, its administrative departments or local authorities, whatever the method of collection.

2. Income taxes shall be deemed to be taxes levied on total income or on part of income, including taxes on profits arising from the disposal of movable or immovable property and taxes on gains in value.

3. The current taxes covered by the contract are:

(a) in the Czechoslovak Socialist Republic:

(i) profit taxes;

(ii) payroll tax;

(iii) income tax on literary and artistic activities;

(iv) agricultural tax;

(v) population income tax; and

(vi) domestic tax,

(hereinafter referred to as "Czechoslovak Tax ');

(b) in the People's Republic of China:

(i) income tax on natural persons;

(ii) income tax on common Chinese and foreign enterprises (joint ventures);

(iii) income tax on foreign companies; and

(iv) local income tax,

(hereinafter referred to as "Chinese tax ').

4. This Treaty shall also apply to taxes of the same or similar kind to be imposed after signature of this Treaty, in addition to or in their place. The competent authorities of the Contracting States shall communicate to each other significant changes made to their respective tax laws.

General definitions

1. Within the meaning of this Treaty, where the link does not require a different interpretation:

(a) the term "Czechoslovakia" refers to the Czechoslovak Socialist Republic;

(b) the term "China" refers to the People's Republic of China;

(c) the terms "one Contracting State" and "the other Contracting State" refer to Czechoslovakia or China, as the case may be;

(d) the term "tax" shall refer to Chinese or Czechoslovak tax as appropriate;

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

(f) the term "company" refers to any legal person or organisational unit considered to be a legal person for taxation purposes;

(g) 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;

(h) the term "nationals" refers to all natural persons who are nationals of a Contracting State and to all legal persons who are incorporated or constituted under the law of that State, as well as to all non-legal organisations deemed to be legal persons who are incorporated or constituted under the law of that Contracting State for taxation purposes;

(i) the term "international transport" shall mean any transport carried out by a ship or aircraft operated by an undertaking whose head office (i.e. actual management) is located in one Contracting State, unless the ship or aircraft is operated only between points in the other Contracting State;

(j) the term "competent authority" shall mean:

(i) in the case of Czechoslovakia, the Minister of Finance of the Czechoslovak Socialist Republic or his authorised representative;

(ii) for China, the Ministry of Finance of the People's Republic of China or its authorised representative.

2. Any term which is not otherwise defined shall have the meaning, under the law of that State, of the Contracting State which governs the taxes to which this Treaty applies, unless the link requires a different interpretation.

Tax domicile

1. The term "resident of one Contracting State" shall, within the meaning of this Treaty, indicate any person who, under the law of that Contracting State, is subject to taxation in that State on account of his residence, permanent residence, head office (i.e. actual management) or any other similar criterion.

2. Where, pursuant to paragraph 1, a natural person is resident in both Contracting States, its status shall be determined in accordance with the following rules:

(a) it is assumed that this person is 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 (centre of life interests);

(b) where 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) if that person is a national of both Contracting States or of any of them, the competent authorities of the Contracting States shall endeavour to adjust the matter by mutual agreement.

3. Where a person other than a natural person is resident in both Contracting States pursuant to paragraph 1, he shall be presumed to be resident in the State in which his head office is located (i.e. actual management).

Permanent establishment

1. The term "permanent establishment" means, within the meaning of this Treaty, a permanent establishment for a business through which an 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 extraction site, quarry or any other place where natural resources are extracted.

3. the term "permanent establishment" also covers:

(a) construction sites, the construction, installation or installation of equipment, or the supervision of such construction sites, the installation or installation of equipment, or the supervision of them, shall last for more than 6 months;

(b) advisory services provided by employees or other staff of an undertaking of one Contracting State in the other Contracting State, provided that such activities continue for one or more connected actions for a continuous period or several periods exceeding a total of 6 months in any 12-month period.

4. Notwithstanding the provisions of paragraphs 1 to 3, the term "permanent establishment 'shall not include:

(a) an establishment 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 facilities which are maintained only for the purpose of carrying out other activities for an undertaking having a preparatory or ancillary character;

(f) assembly services performed by an undertaking of one Contracting State in connection with the sale of machinery or equipment from that Contracting State to the other Contracting State.

5. Notwithstanding the provisions of paragraphs 1 and 2, a person acting in one Contracting State on the behalf of an undertaking of another Contracting State, other than an independent representative to whom paragraph 6 applies, shall be deemed to be a permanent establishment in the former State if, in that State, he is equipped with the full power normally exercised there and allowing him to conclude contracts on behalf of an undertaking, unless the activity of that person is limited to the activities referred to in paragraph 4 which, if carried out in 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 presumed to have a permanent establishment in a Contracting State only because it carries on its business there through a broker, a general agent or any other independent agent, in so far as such persons act in the course of their proper activities. However, where the activities of that representative are wholly or mainly devoted to the interests of the undertaking, that representative shall not be considered as independent within the meaning of this paragraph.

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 business there (whether through a permanent establishment or not) does not in itself make it a permanent establishment of any other company.

Revenue from immovable property

1. Revenue accruing from the resident of one Contracting State from immovable property situated in the other Contracting State (including income from agricultural and forestry undertakings) may be taxed in that other Contracting State.

2. (a) The term "immovable property" subject to subparagraph (b) and (c) shall be defined in accordance with the law of the Contracting State in which the property is located;

(b) the term "immovable property" shall in any case include accessories for immovable property, a dead and a live inventory of agricultural and forestry undertakings and rights to which the provisions of general law applicable to immovable property, the right to use immovable property and the right to variable or fixed salaries for mining or for the admission to mining of mineral deposits, springs and other natural resources apply;

(c) ships and aircraft shall not be regarded as immovable 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 apply in the same way to income from the company's immovable property and to income from immovable property used for the pursuit of an independent profession.

Profits of enterprises

1. The profits of undertakings of one Contracting State shall be taxed only in that State if the undertaking does not carry out its activities in the other Contracting State through a permanent establishment located 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 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 determining the profits of a permanent establishment, the costs incurred in the operation of that permanent establishment, including management costs and general administrative expenses thus incurred, shall be deducted whether they are incurred in the State in which the permanent establishment is located or elsewhere. However, amounts which have been paid (other than as compensation for actual expenses) by the firm's permanent management or by some other office in the form of royalties, refunds or other similar salaries for the use of patents or other rights, or in the form of commission for special services provided, for administration and management, or except in the case of banking firms in the form of interest on money lent to a permanent establishment shall not be allowed. Similarly, when determining the profits of a permanent establishment, no account shall be taken of the amounts which a permanent establishment incurs (otherwise than for actual expenses) on the management or any other office of the holding for royalties, refunds or other similar salaries for the use of patents or other rights, or on commission for special services rendered, for administration and management, or except in the case of banking firms in the form of interest on the money lent to the management or any other office of the firm.

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 State from determining the profits to be taxed by this normal distribution. However, the method of distribution used shall be such that the result is consistent 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.

Transport by ship and air

1. The profits arising from the operation of ships and aircraft in international transport are subject to taxation only in the Contracting State in which the head office (i.e. actual management) of the company is located.

2. Where the head office (i.e. the actual management) of a shipping undertaking is on board a ship, that head office shall be deemed to be located in the Contracting State in which the home port of that ship is or is not a home port in the Contracting State in which the operator of the ship is resident.

3. The provisions of paragraph 1 shall also apply to profits from participation in a pool, joint operation or an international operational organisation.

Associate undertakings

1.

(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 where, in any of these 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, profits of that undertaking may be included and, as a result, taxed profits which would have been achieved without those conditions by one of the undertakings which could not have been achieved in view of those conditions.

2. If the profits from which an undertaking of one Contracting State has been taxed in that Contracting State are also included in the profits of the undertaking of the other Contracting State and those profits thus included are profits which would have been realised by that undertaking of that other State if the conditions agreed between the undertakings were such as would have been agreed between the independent undertakings, the former State shall adjust accordingly the amount of tax levied on those profits in the former State. When establishing such arrangements, due account shall be taken of other provisions of this Treaty and, if necessary, the competent authorities of the Contracting States shall consult each other for that purpose.

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 if the beneficiary is the beneficial owner of dividends, the tax thus determined may not exceed 10% of the gross amount of dividends.

The provisions of this paragraph shall not affect the taxation of the profits of the company serving to pay dividends.

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 profit and income from other shares in companies which, under the law of the State in which the company which pays dividends is resident, is treated as 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 carries out an industrial or commercial activity through a permanent establishment located there or an independent profession through a permanent establishment situated there in the other Contracting State in which the dividend is resident, and where the participation for which the dividends are paid is actually linked to that permanent establishment or to that permanent establishment. In that case, the provisions of Article 7 or Article 14 shall apply as appropriate.

5. Where a company 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 person resident in that other Contracting State, or that the holding for which dividends are paid actually belongs to a permanent establishment or a permanent base located in that other Contracting State, or subject the company's undistributed profits to the tax on undistributed profits, even if the dividends paid or retained earnings remain in whole or in part of the profits or income obtained in that other State.

Interest

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

2. However, such interest may also be taxed in the Contracting State in which the source is located, under the law of that Contracting 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 having a source in one Contracting State and paid to the Government of the other Contracting State, its administrative department, local authority and central bank or any financial institution wholly owned by that Government or another resident of that other Contracting State by way of a claim indirectly financed by the Government of that other Contracting State, its administrative department, the local authority and the central bank or any financial institution wholly owned by that Government shall be exempt from taxation in the former State.

4. The term "interest 'used in this Article refers to income on claims of any kind, secured or not secured by a mortgage on immovable property or a clause relating to participation in the debtor's profits, and in particular income on government securities, bonds and bonds, including premiums and winnings related to such securities, bonds or bonds. Penalties for late payment shall not be considered interest for the purposes of this Article.

5. Paragraphs 1, 2 and 3 shall not apply where the beneficial owner of interest resident in one 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 situated there, and where the claim on which the interest is paid is actually linked to that permanent establishment or to that permanent establishment. In that case, the provisions of Article 7 or Article 14 shall apply as appropriate.

6. Interest shall be assumed to have a source in one Contracting State if the Government of that Contracting State, its administrative department, local authority or person resident in that State is the payer. However, where a payer, whether or not resident in a Contracting State, has a permanent establishment or a permanent base in a Contracting State in respect of which the interest is payable and which bears that interest on its own account, such interest shall be assumed to have a source in the Contracting State in which the permanent establishment or permanent base is located.

7. Where the amount of interest, in view of the claim on which it is paid, exceeds, by reason of the special relationship between the payer and the beneficial owner of the interest or which one or the other maintains with third parties, 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 last amount. In this case, the amount of the salary exceeding it may be taxed under the legislation of each Contracting State and taking into account the other provisions of this Treaty.

Licence fees

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

2. However, such royalties may also be taxed in the Contracting State in which their source is, under the legislation of that State, but if the recipient is the beneficial owner of the royalties, the tax thus fixed shall not exceed 10% of the gross amount of the royalties. The competent authorities of the Contracting States shall, by mutual agreement, determine the manner in which this restriction is applied.

3. The term "licence fees' used in this Article refers to salaries of any kind paid for use or to the right to use the patent, trade mark, model or model, plan, secret formula or production process or industrial, commercial or scientific equipment or to information relating to experience acquired in the field of industrial, commercial or scientific, copyright for the work of literary, artistic or scientific, including cinematographic and television films or radio and television records.

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 located there, or an independent profession through a permanent establishment situated there, and where the right or property giving rise to royalties is actually linked to them. In this case, the provisions of Article 7 or Article 14 may be applied as appropriate.

5. Licensing fees shall be presumed to have a source in one Contracting State if the payer is the government of that Contracting State, its administrative department, local authority or person resident in that Contracting State. However, where a licence fee payer, whether or not resident in a Contracting State, has a permanent establishment or a permanent base in a Contracting State, in conjunction with which the obligation under which the licence fee is payable has been established and which bears such royalties at its expense, those royalties shall be presumed to have a source in the Contracting State in which the permanent establishment or permanent base is located.

6. Where, in view of the use, right or information for which they are paid, the amount of the licence fees exceeds, as a result of the special relations existing between the payer and the beneficial owner or which are maintained by one or the other with third parties, the amount which the debtor 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 last amount. In this case, the amount of the salaries exceeding it shall be taxed under the legislation of each Contracting State and taking into account the other provisions of this Treaty.

Profit from disposal

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

2. Proceeds from the disposal of movable property which is part of the assets of a permanent establishment which is held by an undertaking of one Contracting State in the other Contracting State, or of movable property which belongs 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 resulting 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 a ship or aircraft operating in international transport and movable property which serves the operation of such ships or aircraft shall be taxed only in the Contracting State in which the head office (i.e. actual management) of the undertaking is located.

4. Profit from the disposal of shares in the assets of a company whose assets remain, directly or indirectly, mainly of an immovable asset situated in a Contracting State may be taxed in that Contracting State.

5. Profit from the disposal of shares in companies other than those referred to in paragraph 4 and representing 25% of the participation in a company resident in one Contracting State may be taxed in that Contracting State.

(6) Profit received by a resident of a Contracting State from the disposal of assets other than those referred to in paragraphs 1 to 5 and whose source is in the other Contracting State may be taxed in that other Contracting State.

Independent professions

1. Revenue received by a resident of a Contracting State from a liberal profession or other independent activities shall be taxed 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 beneficiary has a permanent basis for carrying out his activities in the second Contracting State on a regular basis; in that case, only part of the income attributable to that permanent base may be taxed in that other Contracting State; and

(b) if his stay in that other Contracting State lasts for one or more periods in a total of 183 days per calendar year; in this case, only part of the income generated by activities carried out in that other Contracting State may be taxed in that other Contracting State.

2. The term "free profession" shall include, in particular, the activities of scientific, literary, artistic, educational or educational persons, as well as the independent activities of doctors, legal representatives, engineers, architects, dentists and accountants.

Employment

1. The salaries, wages and other similar remuneration which a resident of a Contracting State receives on account of paid employment may, subject to the provisions of Articles 16, 18, 19, 20 and 21, be taxed only in that Contracting State if the employment is not carried out in the other Contracting State. Where there is employment there, the remuneration received for them may be taxed in the latter Contracting State.

(2) Rewards received by a resident of a Contracting State on account of paid employment in the other Contracting State may, notwithstanding the provisions of paragraph 1, be taxed only in the former State if:

(a) the beneficiary shall stay in the other Contracting State for one or more periods not exceeding 183 days in total in a calendar year; and

(b) the remuneration shall be paid by the employer or on behalf of the employer who is not resident in the second Contracting 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 an aircraft in international transport may be taxed only in the Contracting State in which the head office (i.e. actual management) of the undertaking is located.

Tantiems

Tantiémes and other similar remuneration received by a resident of one Contracting State as a member of the Board of Directors of a company resident in the other Contracting State may be taxed in that other State.

Artists and athletes

1. Revenue received by residents of one Contracting State, as public performers, such as theatre, film, radio and television artists and musicians or as athletes, from their activities carried out personally in the other Contracting State, may be taxed, notwithstanding the provisions of Articles 14 and 15.

2. Where the income from an activity carried out personally by an artist or an athlete does not result from that artist or an 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 income of artists and athletes resident in one Contracting State from activities carried out in the other Contracting State in the framework of cultural exchanges between the Governments of the two Contracting States shall be exempt, irrespective of the provisions of paragraphs 1 and 2, from taxation in that other Contracting State.

Pension

1. Pensions and other similar salaries paid on account of former employment of a resident of a Contracting State may be taxed only in that Contracting State, subject to the provisions of Article 19 (2).

2. The pensions and other similar salaries paid by the Government of a Contracting State, by its administrative department or by a local authority under the social security schemes of that Contracting State, irrespective of the provisions of paragraph 1, shall be taxed only in that Contracting State.

Public functions

1. (a) Rewards, other than pensions, paid by the Government of a Contracting State, by its administrative department or by a local authority to a natural person for services provided to the Government of that Contracting State, its administrative department or local authority for services of a governmental nature shall be taxed only in that Contracting State.

(b) However, such remuneration shall be taxed only in the second Contracting State where the services are demonstrated in that second Contracting State and the recipient is resident in that second Contracting State which:

(i) is a State citizen of the other Contracting State; or

(ii) he did not become resident in that other Contracting State solely because of the provision of such services.

2. (a) The pensions paid by the Government of a Contracting State, by its administrative department or by a local authority of that State either directly or from the funds which they have set up, to a natural person for services rendered by the Government of that Contracting State, its administrative department or local authority shall be taxed only in that Contracting State.

(b) Such pensions shall, however, be taxed only in the second Contracting State if the beneficiary is resident and a State citizen of that second Contracting State.

(3) The provisions of Articles 15, 16, 17 and 18 shall apply to the remuneration and pensions of services shown in connection with an industrial or commercial activity carried out by the Government of a Contracting State, its administrative department or local authority.

Teachers and researchers

Remuneration which a person who is, or was, resident in the other Contracting State immediately prior to the arrival of a Contracting State and who is present in the former Contracting State for the purpose of teaching, lecturing or conducting research at a university, university, school or other educational institution or a scientific research institution entrusted with the Government of the former Contracting State, shall be exempt from tax in that former Contracting State for a period not exceeding 5 years from the date of its first arrival in the former Contracting State.

Students, apprentices and trainees

1. A student, apprentice or intern who is, or was, a resident in the other Contracting State immediately prior to his or her arrival in one Contracting State and who resides in the former State only for the purpose of study or training shall be exempt in that Contracting State from tax on:

(a) salaries for the cost of nutrition, study or training received from abroad;

(b) scholarships, donations, allowances and bonuses from governmental, charitable, scientific, cultural or educational organisations received for the purpose of paying the cost of nutrition, study or training.

2. The student, apprentice or intern referred to in paragraph 1 shall enjoy, in respect of remuneration for employment, the same exceptions, reductions or reductions as those of the residents of the Contracting State which he has visited during this study or training.

Citation	Decree of the Minister for Foreign Affairs No. 41 / 1988 Coll., on the Treaty between the Government of the Czechoslovak Socialist Republic and the Government of the People's Republic of China on the avoidance of double taxation and the prevention of tax evasion in the field of income tax
Regulation Type	-
Author	-
Collection	Code of Laws

Date of Promulgation	15.04.1988
Effective from	23.12.1987
Effective until	-
Status	Valid

Decree of the Minister for Foreign Affairs on the Treaty between the Government of the Czechoslovak Socialist Republic and the Government of the People's Republic of China on the avoidance of double taxation and the prevention of tax evasion in the field of income taxes

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