Communication from the Ministry of Foreign Affairs No. 439 / 2024 Coll.

The Ministry of Foreign Affairs announces that on 16 August 2024 the Czech Republic notified the depositary of the Multilateral Convention on the implementation of measures to combat tax base reduction and transfer of profits in relation to tax agreements the following additional notifications:

"Additional notification by the Czech Republic to the Multilateral Convention on the Implementation of Measures to Combat Reducing Tax Basis and Transfer of Profit in relation to Tax Contracts, signed in Paris on 7 June 2017

1. Pursuant to Article 29 (5) of the Convention, the Czech Republic provides that all the subsequent notified contracts listed below are covered by all the reservations made by the Czech Republic in the deposit of the instrument of ratification on 13 May 2020.

Notice to extend the provisional list of contracts covered by the Convention

Pursuant to Article 29 (5) of the Convention, the Czech Republic extends the list of contracts covered by the Convention on the following contracts:

Number Name Second contractual jurisdiction Original / Protocol Date of entry into force 53Treaty between the Czech Republic and the Republic of Albania on the avoidance of double taxation and on the prevention of tax evasion in the field of income and property taxes Albania Original22-06-199510-09-199654Treaty between the Government of the Czech Republic and the Government of the Republic of Azerbaijan on the avoidance of double taxation and the prevention of tax evasion in the field of income taxes and property of Azerbaijan Original24-11-200516-06-200655Treaty between the Government of the Czech Republic and the Government of the Kingdom of Bahrain on the avoidance of double taxation and tax evasion in the field of income taxes BahrajnOriginál24-05-201110-04-201256Treaty between the Government of the Czech Republic and the Government of Barbados on the avoidance of double taxation and tax evasion in the field of income taxes BarbadosOriginál26-10-201106-06- 201257Treaty between the Czech Republic and Bosnia and Herzegovina on the prevention of double taxation and tax evasion in the field of income and property taxes Bosnia and Herzegovina Original20-11-200712-05-201058Treaty between the Czech Republic and the Republic of Estonia on the prevention of double taxation and the prevention of tax evasion in the field of income taxes and property Original 24-10-199426-05- 199559 Agreement between the Government of the Czech Republic and the Government of the Republic of Indonesia on the avoidance of double taxation and the prevention of tax evasion in the field of income taxes Indonesia Original04-10-199426-01- 199660 Agreement between the Government of the Czech Republic and the Government of the Hashemite Kingdom of Jordan on the avoidance of double taxation and the prevention of tax evasion in the field of income taxes Jordan Original 10-04-200607-11-200761Agreement between the Czech Republic and the Republic of Kazakhstan on the avoidance of double taxation and the prevention of tax evasion in the field of income and property taxes Kazakhstan Original09-04-199829-10-1999 Protocol 24-11-201428-06-201662Agreement between the Government of the Czech Republic and the Government of Malaysia on the avoidance of double taxation and the prevention of tax evasion in the field of income tax Malaysia Original08-03-199609-03-199863Treaty between the Czech Republic and Mongolia on the prevention of double taxation and the prevention of tax evasion in the field of income taxes and property Original27-02-199722-06-199864Agreement between the Czech Republic and the Kingdom of Morocco on the avoidance of double taxation and the prevention of tax evasion in the field of income tax MarokOOriginal11-06-200118-07-200665Agreement between the Czech Republic and the Republic of Macedonia on the prevention of double taxation and the prevention of tax evasion in the field of income and property taxes Northern Macedonia Original21-06-200117-06-200266Agreement between the Czech Republic and the Republic of Panama to avoid double taxation and prevent tax evasion in the field of income tax PanamaOriginál04-07-201225- 02- 201367Treaty between the Government of the Czech Republic and the Government of the Kingdom of Saudi Arabia on the prevention of double taxation and the prevention of tax evasion in the field of income taxes Saudi Arabia Original25-04-201201-05-201368Treaty between the Government of the Czech Republic and the Royal Government of the Kingdom of Thailand on the prevention of double taxation and tax evasion in the field of income taxes Thailand Original 12- 02- 199414- 08- 199569 Agreement between the Government of the Czechoslovak Socialist Republic and the Government of the Republic of Tunisia on the avoidance of double taxation and the prevention of tax evasion in the field of income and property taxes Tunisia Original14-03-199025-10- 199170 Agreement between the Government of the Czech Republic and the Government of Ukraine on the avoidance of double taxation and the prevention of tax evasion in the field of income and property taxes Ukraine Original30-06-199720-04-1999 Protocol 21-10-201309-12-201571Agreement between the Government of the Czech Republic and the Government of the Socialist Republic of Vietnam on the avoidance of double taxation and the prevention of tax evasion in the field of income and property taxes Vietnam

Article 6 - Objective of contracts covered

Notice resulting from the extension of the list of contracts covered by the Convention

Following the extension of the list of contracts covered by the Convention pursuant to Article 29 (5) of the Convention, the Czech Republic considers that, pursuant to Article 6 (5) of the Convention, the following contracts are outside the scope of the reservation provided for in Article 6 (4) and contain the preamble text referred to in Article 6 (2). The text of the relevant paragraph of the preamble is given below.

Contract number on the list Second contractual jurisdiction Preamble Text 53Albania < Desiring to conclude, in order to further develop and facilitate its economic relations, > To conclude a Double Taxation Agreement and to prevent tax evasion in the field of income and property, 54Azerbaijan wishes to conclude a Double Taxation Agreement and to prevent tax evasion in the field of income and property, 55Bahrain wishes to conclude a Double Taxation Agreement and to prevent tax evasion in the field of income and property tax, 56Barbadodo wishes to conclude a Double Taxation Treaty and to prevent tax evasion in the field of income, 57Bosnia and Herzegovina wishing to conclude a Double Taxation Treaty and to prevent tax evasion in the field of income and property, 58 Estonia desiring to conclude a double taxation contract and to prevent tax evasion in the income tax and property tax sector, 59Indonesia desiring to conclude a double taxation contract and to prevent tax evasion in the income tax sector, 60Jordan desiring to conclude a double taxation contract and to prevent tax evasion in the income tax sector, 61Kazakhstan desiring to conclude a double taxation agreement and to prevent tax evasion in the income tax and property sector, 62Malaysia desiring to conclude a double taxation and tax evasion in the income tax sector, 63 Mongolia wishes to conclude a double taxation contract and prevent tax evasion in the field of income and property taxes, 64Morocco wishes to conclude a double taxation contract and to prevent tax evasion in the field of income taxes, 65North Macedonia wishes to conclude a double taxation agreement and to prevent tax evasion in the field of income and property taxes, 66 Paging to conclude a double taxation contract and prevent tax evasion in the income tax sector, 67Saudi Arabia wishes to conclude a double taxation contract and prevent tax evasion in the income tax sector, 68Thailand wishes to conclude a double taxation and tax evasion in the income tax sector, 69Tunisia wishes to conclude a double taxation and tax evasion contract in the income tax and property sector Wishing to conclude a Double Taxation Treaty and to prevent tax evasion in the field of income taxes and wealth < and confirming their efforts to develop and deepen economic relations, > 71Vietnam wishing to conclude a Double Taxation Treaty and to prevent tax evasion in the field of income taxes and property tax,

Article 7 - Preventing misuse of the contract

Notification of the selection of optional provisions

Following the extension of the list of contracts covered by the Convention pursuant to Article 29 (5) of the Convention, the Czech Republic hereby chooses to apply Article 7 (4) to all additional contracts covered pursuant to Article 7 (17) (b) of the Convention.

Notification as a result of the extension of the list of documents covered by the Convention

Following the extension of the list of contracts covered by the Convention pursuant to Article 29 (5) of the Convention, the Czech Republic considers that, pursuant to Article 7 (17) (a) of the Convention, the following contracts are not subject to the reservation provided for in Article 7 (15) (b) and contain the provisions referred to in Article 7 (2). The number of the article and paragraph of each such provision shall be as follows.

Contract number on the list Second contractual jurisdiction Establishing a 54Azerbaijan Protocol 455Bahrain Article 2656BarbadosArticle 27 (4) 60Jordan Article 27 (2) 66PanamArticle 26 (2) 67Saudi Arabia Article 27 (2) 70 Ukraine Additional Protocol 15 (a), 15 (c)

Article 16 - Solving cases by agreement

Notification as a result of the extension of the list of contracts covered by the Convention

Following the extension of the list of contracts covered by the Convention pursuant to Article 29 (5) of the Convention, the Czech Republic considers that, pursuant to Article 16 (6) (a) of the Convention, the following Treaties contain the provisions referred to in Article 16 (4) (a) (i). The number of the article and paragraph of each such provision shall be as follows. Contract number on the list Second contractual jurisdiction Article 53Albania Article 26 (1), first sentence 54Azerbaijan Article 25 (1), first sentence 55Bahrain Article 23 (1), first sentence 56BarbadosArticle 24 (1), first sentence 57Bosnia and Herzegovina Article 24 (1), first sentence 58Estonia Article 25 (1), first sentence 59Indonesia Article 24 (1) 60Jordan Article 24 (1), first sentence 61Kazakhstan Article 25 (1), first sentence 62Malaysia Article 26 (1) 63Mongolia Article 26 (1), first sentence 64Morocco Article 25 (1), first sentence Article 25 (1), first sentence 70Ukraine Article 25 (1), first sentence 71Vietnam Article 25 (1), first sentence

Following the extension of the list of contracts covered by the Convention pursuant to Article 29 (5) of the Convention, the Czech Republic considers that under Article 16 (6) (b) (ii), The conventions of the following Treaties contain a provision providing that the case referred to in the first sentence of Article 16 (1) must be submitted within a certain period of time, which shall be at least three years from the first notification of a measure leading to taxation which does not comply with the provisions covered by the contract. The number of the article and paragraph of each such provision shall be as follows.

Contract number on the list Second contractual jurisdiction Article 53Albania Article 26 (1), second sentence 54Azerbaijan Article 25 (1), second sentence 55Bahrain Article 23 (1), second sentence 56BarbadosArticle 24 (1), second sentence 57Bosnia and Herzegovina Article 24 (1), second sentence 58Estonia Article 25 (1), second sentence 60Jordan Article 24 (1), second sentence 61Kazakhstan Article 25 (1), second sentence 67Saudi Arabia Article 25 (1), second sentence 64Morocco Article 25 (1), second sentence 65North Macedonia Article 24 (1), second sentence 66Panama Article 23 (1), second sentence 67Saudi Arabia Article 24 (1), second sentence 68Rule 25 (1)

Following the extension of the list of contracts covered by the Convention pursuant to Article 29 (5) of the Convention, the Czech Republic considers that, pursuant to Article 16 (6) (c) (ii), The following conventions shall not contain the provisions referred to in Article 16 (4) (b) (ii).

Contract number on the list Second contractual jurisdiction 59 Indonesia 62Malaysia-68Thailand

Following the extension of the list of contracts covered by the Convention pursuant to Article 29 (5) of the Convention, the Czech Republic considers that under Article 16 (6) (d) (ii) of the Convention: The Convention does not contain the provisions referred to in Article 16 (4) (c) (ii).

Contract number on the list Second contractual jurisdiction 69 Tunisia

2. The Czech Republic makes a notification for the purpose of correcting the English name of the Treaty previously notified under number 52. The correct title is "The Agreement between the Government of the Czech and Slovak Federal Republic and the Government of the United Kingdom of Great Britain and Northern Ireland on the avoidance of double taxation in the field of income tax and property gains." '