Decree of the Minister for Foreign Affairs No. 46 / 1979 Coll.
Decree of the Minister for Foreign Affairs on the Treaty between the Czechoslovak Socialist Republic and Japan on the avoidance of double taxation in the field of income taxes
Valid
Effective from 25.11.1978
46
DECLARATION
Minister for Foreign Affairs
of 18 January 1979
on the Treaty between the Czechoslovak Socialist Republic and Japan on the avoidance of double taxation in the field of income taxes
The Treaty between the Czechoslovak Socialist Republic and Japan on the avoidance of double taxation in the field of income taxes was signed in Prague on 11 October 1977.
The Treaty was approved by the Federal Assembly of the Czechoslovak Socialist Republic and ratified by the President of the Republic. The instruments of ratification were exchanged in Tokyo on 26 October 1978.
The Treaty entered into force on 25 November 1978 pursuant to Article 28 thereof.
The Czech translation of the text of the Treaty is announced simultaneously.
Minister:
Ing. Chupek v. r.
TREATY
between the Czechoslovak Socialist Republic and Japan on the avoidance of double taxation in the field of income taxes
Czechoslovak Socialist Republic and Japan,
Desiring to conclude a double taxation contract in the field of income tax,
agree as follows:
This Treaty shall apply to persons residing or having their registered office in one or both Contracting States.
1. the taxes covered by this Treaty shall be:
(a) In Japan:
(i) income tax,
(ii) company tax; and
(iii) local population tax
(hereinafter referred to as the "Japanese tax ').
(b) In Czechoslovakia:
(i) profit payment and profit tax,
(ii) payroll tax,
(iii) income tax on literary and artistic activities,
(iv) agricultural tax,
(v) population income tax; and
(vi) Home tax
(hereinafter referred to as "Czechoslovak Tax ').
2. The contract shall also apply to all identical or substantially similar taxes to be levied upon signature of the contract in addition to or in place of the taxes referred to in the preceding paragraph. The competent authorities of the Contracting States shall notify each other within a reasonable period of time of any changes to be made to their respective tax laws.
1. In this Treaty, unless the link requires a different interpretation:
(a) The term "Japan," when used in the geographical sense, refers to all territories in which the laws governing Japanese tax apply.
b) The term "Czechoslovakia" refers to the Czechoslovak Socialist Republic.
(c) The terms "one Contracting State" and "the other Contracting State" refer to Japan or Czechoslovakia as the link requires.
(d) The term "tax" refers to a Japanese tax or a Czechoslovak tax, as the context requires.
(e) The term "person" shall include natural persons, companies and any other association of persons.
(f) The term "company" shall refer to any legal person or substance considered to be a legal entity for tax purposes.
(g) The terms "undertaking of one Contracting State" and "undertaking of the other Contracting State" refer to an undertaking operated by a person resident or established in one Contracting State or, where appropriate, an undertaking operated by a person residing or having its registered office in the other Contracting State.
(h) The term "members" refers to all natural persons who are nationals of a Contracting State, to all legal persons established or organised under the law of a Contracting State, and to all organisations without legal personality which, for the purposes of taxation of that Contracting State, are regarded as legal persons established or organised under the law of that Contracting State.
(i) The term "competent authority" in relation to a Contracting State shall refer to the Minister of Finance of that Contracting State or its authorised representative.
(j) The term "international transport" shall mean any transport carried out by a ship or aircraft operating by an undertaking of a Contracting State where the ship or aircraft is not used only between places situated in the other Contracting State.
2. Any term which is not otherwise defined in the Treaty shall have a meaning for the application of this Treaty by the Contracting State which is addressed to it by the legislation of that Contracting State governing taxes which are the subject of this Treaty, unless the link requires a different interpretation.
1. For the purposes of this Treaty, the term "resident or domiciled person" shall mean any person who is subject to taxation under the laws of that Contracting State by reason of his residence, residence, principal administration, place of administration or any other criterion of a similar nature. The term does not cover natural persons subject to taxation in that Contracting State only because they receive income from resources located in that State.
2. Where, pursuant to paragraph 1, a natural person resides in both Contracting States, the competent authorities shall decide by common accord in which State the natural person is deemed to be resident for the purposes of this Treaty.
3. Where a person other than a natural person has its registered office in both Contracting States in accordance with the provisions of paragraph 1, it shall be presumed to have its registered office in the Contracting State in which the place of its main administration is situated.
1. For the purposes of this Treaty, the term "permanent establishment" shall mean 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) place of management;
(b) the race;
(c) an office;
(d) the factory,
(e) workshop,
(f) mine, quarry, or other place where natural resources are extracted;
(g) construction sites or installations lasting more than 12 months.
3. the term "permanent establishment" does not cover:
(a) equipment used only for the storage, display or supply of goods belonging to the holding;
(b) goods belonging to an undertaking which is stored only as a stock for the purpose of exhibition or delivery;
(c) goods belonging to an undertaking which is stored only for processing by another undertaking;
(d) permanent establishment serving business which is used only for the purpose of purchasing goods or collecting information for the undertaking;
(e) permanent establishment serving business which is used for the purposes of advertising only, the provision of information, scientific research or similar activities of a preparatory or auxiliary nature;
(f) the assembly carried out by an undertaking of one Contracting State in conjunction with the supply of machinery or equipment from that Contracting State to the other Contracting State.
4. A person acting in one Contracting State for an undertaking of the other Contracting State - other than a representative having an independent status as referred to in paragraph 5 - shall be deemed to be a permanent establishment in the former Contracting State if, in that former Contracting State, he is equipped with the full power that he normally uses there and allows him to conclude contracts on behalf of an undertaking, unless the activity of that person is limited to buying goods for an undertaking.
5. In the other Contracting State, the mere fact that an undertaking in that other Contracting State carries on its business through a broker, a general agent or any other representative having an independent position shall not be regarded as a permanent establishment of an undertaking of one Contracting State where such persons act in the proper course of their business.
6. The fact that a company which has its registered office in one Contracting State controls the company or is controlled by a company which has its registered office in the other Contracting State or which carries out its business in that other Contracting State (whether through a permanent establishment or otherwise) does not in itself make it a permanent establishment of the other company.
1. Revenue from immovable property may be taxed in the Contracting State in which such property is located.
2. The term "immovable property" shall be defined in accordance with the law of the Contracting State in which such property is located. The term covers, in any case, accessories for immovable property, both live and dead inventories of agricultural and forestry holdings, rights covered by the provisions of civil law on immovable property, the consumption of immovable property and the right to variable or fixed benefits, paid as compensation for mining or the right to mine mineral deposits, springs and other natural resources. Ships and aircraft shall not be considered immovable property.
3. Paragraph 1 shall apply to income from direct use, rental or any other use of immovable property.
4. The provisions of paragraphs 1 and 3 shall also apply to income from the immovable property of an undertaking and to income from immovable property used for the exercise of a professional profession.
1. The profit of an undertaking of one Contracting State shall be subject to taxation only in that Contracting State, unless the undertaking carries out its business in the other Contracting State through a permanent establishment situated there. Where an undertaking carries out its business in this way, the profits of the undertaking may be taxed in the other Contracting 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 in each Contracting State to that permanent establishment a profit which it is expected to achieve if, as a separate undertaking, it carries out identical or similar activities under the same or similar conditions and trade completely independently with the undertaking of which it is a permanent establishment.
3. In calculating the profit of a permanent establishment, the costs incurred for the objectives pursued by that permanent establishment, including management costs and general administrative expenses thus incurred, shall be deducted, whether in the Contracting State in which the permanent establishment is located or elsewhere.
4. Where, in a Contracting State, it is customary to determine the profit to be added to a permanent establishment on the basis of the distribution of the company's total profits by its different parts, nothing in paragraph 2 shall prevent that Contracting State from determining the profit to be taxed by such distribution as is usual. However, the method of division adopted shall be such that the result is consistent with the principles set out in this Article.
5. No profit shall be added to the permanent establishment on the basis that it only purchased goods for the undertaking.
(6) For the purposes of the preceding paragraphs, the profit to be attributed to a permanent establishment shall be calculated each year on the basis of the same method, unless there are serious and sufficient grounds for a different procedure.
7. Where the profit includes parts of income which are treated separately in other Articles of this Treaty, the provisions of this Article shall not affect those Articles.
1. Profit from the operation of ships or aircraft in international transport carried out by an undertaking of a Contracting State shall be subject to taxation only in that Contracting State.
2. As regards the implementation of international maritime or air transport by an undertaking of a contracting State, such an undertaking, if it is a Czechoslovak undertaking, shall be exempt from trade tax in Japan, and the Japanese undertaking shall be exempt from any tax similar to Japanese trade tax if it were collected later in Czechoslovakia.
3. The provisions of paragraphs 1 and 2 shall also apply to profit from participation in a pool, joint operation or an international operational organisation.
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 one and the other cases, conditions have been negotiated or imposed between the two undertakings in their commercial or financial relations, which differ from those which would have been agreed between independent undertakings, a profit which would have been achieved without such conditions by one of the undertakings, but which, in view of these conditions, was not achieved, may be included in the profits of that undertaking and taxed.
1. Dividends paid by a company having its registered office in one Contracting State, to a person residing or having its registered office in the other Contracting State, may be taxed in that other Contracting State.
2. However, these dividends may be taxed in the Contracting State in which the company which pays them has its registered office under the law of that Contracting State. However, the tax thus determined shall not exceed:
(a) 10% of the gross amount of dividends where the beneficiary is a company which holds at least 25% of the shares in the right to vote in the companies paying dividends for the six months immediately preceding the date of payment of such dividends;
(b) 15% 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 shall refer to income arising from shares or other rights, with the exception of profit-participation claims, as well as income from other social rights, which is assimilated to income from shares by the tax provisions of the Contracting State in which the dividend company is established.
4. The provisions of paragraphs 1 and 2 shall not apply where the beneficiary of dividends, residing or having his registered office in one Contracting State, has a permanent establishment in the other Contracting State in which the company paying dividends has its registered office, which is actually linked to the ownership of the shares on the basis of which the dividends are paid. In that case, the provisions of Article 7 shall apply.
5. Where a company having its registered office in one Contracting State achieves a profit or income from the other Contracting State, that other Contracting State may not levy any tax on dividends paid by the company to persons who do not have their registered office in that other Contracting State or subject the company's undistributed profits to a tax on undistributed profits, even if the dividends paid or the earnings distributed remain in whole or in part of the profits or income derived from that other Contracting State.
1. Interest, having a source in one Contracting State and paid to a person domiciled or domiciled in the other Contracting State, may be taxed in that other Contracting State.
2. However, such interest may be taxed in the Contracting State in which its source is located, under the law of that Contracting State. However, the tax thus fixed shall not exceed 10% of the gross amount of interest.
3. Interest, having a source in one Contracting State and paid to the Government of the other Contracting State, its local authorities, the central bank of that other Contracting State or a financial institution wholly owned by that State, or a person domiciled in that other Contracting State, on claims secured or indirectly financed by the Government of that other Contracting State, its local authorities, the central bank of that other Contracting State or the financial institution wholly owned by that State, shall be exempt from tax in the former Contracting State, notwithstanding the provisions of paragraph 2.
4. The term "interest 'used in this Article refers to income on public bonds, bonds, secured and unsecured by a lien on immovable property, whether or not providing the right to participate in profits, and other claims of any kind, any difference by which the amount paid to settle such claims exceeds the amount of the loan, as well as any other income which is built by the tax legislation of the Contracting State in which the source of the income is the income from the loans.
5. The provisions of paragraphs 1 and 2 shall not apply where the beneficiary of an interest which is resident or established in one Contracting State has a permanent establishment in the other Contracting State in which the interest is due, with which the claim is actually linked, which is the source of interest. In this case, the provisions of Article 7 shall apply.
6. Interest shall be assumed to have a source in a particular Contracting State, if the payer is the Contracting State itself, its local office or person residing or having its registered office in that Contracting State. However, if the person who pays interest, whether he is resident or not in a Contracting State, has a permanent establishment in a Contracting State in conjunction with which the debt on which the interest is payable has been incurred and if such interest is borne by that permanent establishment at its expense, it shall be assumed that such interest shall have a source in the Contracting State in which the permanent establishment is situated.
7. Where the amount of interest paid, in view of the claim on which it is paid, exceeds the amount which would have been agreed with the payee by the payer 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 part of the salary exceeding that shall be subject to taxation under the legislation of each Contracting State, taking into account the other provisions of this Treaty.
1. Licensing fees having a source in one Contracting State and paid to a person residing or having his registered office in the other Contracting State may be taxed in that other Contracting State.
2. (a) Industrial licence fees may be taxed in the Contracting State in which their source is located, under the legislation of that Contracting State. However, the tax thus fixed shall not exceed 10% of the gross amount of royalties.
(b) Cultural licence fees shall be exempt from taxes in the Contracting State in which their source is.
3. (a) The term "industrial licence fees" used in paragraph 2 shall refer to the salaries of any kind received by a refund for use or for the right to use any patent, trade mark, trade mark, design or model, plan, secret instruction or production process, or for use or for the right to use industrial, commercial or scientific equipment, or for information relating to experience acquired in the field of industrial, commercial or scientific.
(b) The term "cultural licence fees" used in paragraph 2 shall refer to salaries of any kind accepted 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 tapes for radio or television broadcasting.
4. The provisions of paragraphs 1 and 2 shall not apply where the recipient of royalties residing or having his registered office in one Contracting State has a permanent establishment in the other Contracting State in which the royalties have a source, a permanent establishment with which the right or property which is a source of royalties is actually linked. In that case, the provisions of Article 7 shall apply.
5. Licensing fees shall be presumed to have a source in a particular Contracting State, if the payer is that Contracting State itself, its local office or person residing or having its registered office in that Contracting State. However, where a person who pays royalties, whether or not he is domiciled in a Contracting State, has a permanent establishment in a Contracting State, in conjunction with which an obligation to pay royalties has arisen, and where such royalties are borne by that permanent establishment, those royalties shall be presumed to have a source in the Contracting State in which the permanent establishment is situated.
6. Where the amount of royalties paid, assessed in the light of the use, right or information for which they are paid, exceeds, as a result of the special relations existing between the payer and the payee, or between the two and a third party, the amount which the payer would have agreed with the payee if it had not been for such relations, the provisions of this Article shall apply only to that last amount. In this case, the part of the salaries exceeding it shall be subject to taxation under the legislation of each Contracting State, taking into account the other provisions of this Treaty.
(1) Profit from the disposal of immovable property the definition of which is set out in Article 6 (2) may be taxed in the Contracting State in which such property is located.
2. Profit from the disposal of any property other than immovable 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 of any property other than immovable property belonging to a permanent base which is owned by a person residing in one Contracting State in the other Contracting State for the pursuit of a professional activity, including the profit from the disposal of such permanent establishment (alone or together with the whole undertaking) or such permanent base, may be taxed in that other Contracting State. However, profits made by a person resident or established in a Contracting State from the disposal of ships or aircraft used in international transport and any property other than property belonging to the operation of such ships or aircraft shall be subject to taxation only in that Contracting State.
3. Profit realised by a person resident or domiciled in a Contracting State from the disposal of assets other than those referred to in paragraphs 1 and 2 shall be subject to taxation only in that Contracting State.
1. The income which a person resident in one Contracting State receives for services rendered in the course of a professional or other independent activity of a similar nature shall be subject to taxation only in that Contracting State, unless that person has a permanent basis for the performance of his activities in the other Contracting State. If it has such a permanent base, the 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 professions" includes the particularly independent activities of scientific, literary, artistic, educational or teaching, and independent activities of doctors, lawyers, engineers, architects, dentists and accountants.
1. Wages, salaries and other similar remuneration which a person residing in one Contracting State receives on account of employment shall be subject, subject to the provisions of Articles 16, 18, 19, 20 and 21, to taxation in that Contracting State only if the employment is not carried out in the other Contracting State. If there is employment there, the remuneration received from that employment may be taxed in the latter Contracting State.
2. The remuneration received by a person residing in one Contracting State for employment in the other Contracting State shall be subject, notwithstanding the provisions of paragraph 1, to taxation only in the former Contracting State where:
(a) the consignee shall stay in that other Contracting State for one or more periods not exceeding 183 days in total in the relevant calendar year; and
(b) the remuneration shall be paid by the employer or in the name of the employer who is not domiciled in the latter Contracting State; and
(c) the remuneration shall not be borne by a permanent establishment or a permanent base held by the employer in that other Contracting State.
3. Remuneration on account of employment carried on board a ship or aircraft used in international transport by an undertaking of a Contracting State may be taxed in that Contracting State, irrespective of the previous provisions of this Article.
The remuneration which a person resident in a Contracting State receives as a member of the administrative or supervisory board of a company having its registered office in the other Contracting State may be taxed in that other Contracting State.
1. The income received by publicly performing theatre, film, radio or television artists and musicians or athletes from this personal activity may be taxed in the Contracting State in which the activities of artists and athletes are carried out, irrespective of the provisions of Articles 14 and 15.
However, such income shall be exempt in that Contracting State if such activities are carried out by natural persons resident in the other Contracting State under a specific cultural exchange programme agreed by the Governments of both Contracting States.
2. Where an income relating to the personal activity of artists or athletes is not attributable to that artist or sportsman himself but to another person, that income may be taxed, irrespective of the provisions of Articles 7, 14 and 15, in the Contracting State in which the activities of the artist or sportsman are carried out.
However, such income shall be exempt in that Contracting State if it is received from activities carried out by natural persons residing in the other Contracting State under a specific programme of cultural exchanges agreed by the Governments of the two Contracting States and if that income is attributable to another person residing or residing in that other Contracting State.
Pensions and other similar salaries, referred to by reason of former employment to a person residing in a Contracting State and any regular wage repayable to that person shall be subject to taxation only in that Contracting State.
1. (a) Rewards other than pensions paid by a Contracting State or its local authority to a natural person for services demonstrated to that Contracting State or its local authority in the performance of official duties shall be subject to taxation only in that Contracting State.
(b) Such remuneration shall, however, be subject to taxation only in the second Contracting State where the services have been demonstrated in that second Contracting State, the beneficiary shall reside in that second Contracting State; and
(i) is a State citizen of that other Contracting State; or
(ii) has not obtained residence in that other Contracting State solely for the purpose of carrying out such services.
2. (a) Any pension paid by a Contracting State or its local authority or from the funds to which they grant contributions shall be subject to taxation only in that Contracting State for the services shown to that Contracting State or its local office.
(b) Such pensions shall, however, be subject to taxation only in the second Contracting State where the recipient of the pension is a national citizen of that second Contracting State and is resident in that second Contracting State.
3. The provisions of Articles 15, 16, 17 and 18 shall apply to remuneration and pensions paid for services demonstrated in connection with an industrial or commercial activity carried out by a Contracting State or its local authority.
1. A professor or teacher who has temporarily visited a contracting State for a period not exceeding two years to teach or conduct research work there at a university, college, school or other recognised educational institution and who has, or immediately before such a visit, been resident in a second Contracting State shall be liable only in that other Contracting State to the tax on the remuneration of such teaching or research.
2. Paragraph 1 shall not apply to income from research activities where such research is carried out primarily for the private benefit of a person or persons.
The salary or income which he receives for the cost of his or her nutrition, education or practice as a student or apprentice who resides in a Contracting State only for the purpose of his or her education, training or obtaining special technical experience and who is resident or immediately prior to his or her residence in the other Contracting State shall be exempt from tax in the former State if such payments have been made to him in that former State from abroad, or if he has received such income for his or her personal services as demonstrated in the former Contracting State not exceeding 600 000 Japanese yen or their consideration in the Czechoslovak crowns during any tax year.
Parts of the income of a person residing or having his registered office in a Contracting State not specifically mentioned in the preceding Articles of this Treaty shall be subject to taxation only in that State.
Double taxation of income shall be excluded as follows:
(a) Where a person resident or domiciled in Japan receives income from Czechoslovakia and where such income can be taxed in both Contracting States under the provisions of this Treaty, the amount of Czechoslovak tax payable on that income shall be credited to that person under the Japanese rules on the deduction of foreign tax on Japanese tax. However, the amount to be credited shall not exceed that part of the Japanese tax, which is proportional to that income.
(b) (i) Where a person residing or having his registered office in Czechoslovakia receives income which may be taxed in Japan under the provisions of this Treaty, Czechoslovakia shall, subject to paragraph (ii), exempt such income from taxation. However, when calculating the tax on the other income of that person, it may apply the rate of tax which would have been applied if the exempt income had not been thus excluded from taxation.
(ii) If a resident or registered office in Czechoslovakia receives income which may be taxed in Japan under the provisions of Articles 10, 11, 12, 16 and 17 of this Treaty, it shall allow Czechoslovakia to reduce the income tax of that person by an amount equal to that paid in Japan. However, the amount by which the tax is to be reduced shall not exceed that part of the Czechoslovak tax calculated before the tax reduction was allowed, which is proportional to the income taxed in Japan under Articles 10, 11, 12, 16 and 17 of this Treaty.
(iii) The contributions paid by Czechoslovak state economic organisations to the state budget shall be considered a Czechoslovak tax.
1. The members of one Contracting State, whether or not they have their domicile or registered office in a Contracting State, shall not be subject in the other Contracting State to any taxation or obligations associated with it which would be different or more burdensome than that of taxation and to which the members of that other Contracting State are or may be subject in the same circumstances.
2. The taxation of a permanent establishment held by an undertaking of one Contracting State in the other Contracting State shall not be made in a less favourable manner in that other Contracting State than that of the undertakings of that other Contracting State which carry out the same activity.
This provision shall not be construed as an obligation of one Contracting State to grant persons residing in the other Contracting State personal reductions, discounts and reductions on account of their personal status or obligations as a family which it grants to persons residing in its territory.
3. Undertakings of one Contracting State whose assets are wholly or partly owned, directly or indirectly owned or controlled by a person or persons domiciled in the other Contracting State shall not be subject in the former Contracting State to any taxation or obligations associated with it which are different from or more burdensome than taxation and to which other similar undertakings of that former State are or may be subject.
4. The term "taxation" refers to taxes of any kind and names in this article.
1. Where a person residing or having his registered office in a Contracting State considers that the measures taken by one or both Contracting States have, or will have, the effect on him of taxation which is not in accordance with this Treaty, he may, irrespective of the remedies provided by the legislature of those Contracting States, refer his case to the competent authority of the Contracting State in which he resides or has his registered office.
2. The competent authority shall endeavour to adjust the question by mutual agreement with the competent authority of the other Contracting State in order to avoid taxation which is not in conformity with this Treaty if it considers the objection to be justified and if it itself is unable to find a satisfactory solution.
3. The competent authorities of the Contracting States shall endeavour to resolve problems or doubts which may arise in the interpretation or application of this Treaty by mutual agreement. They may also consult each other to exclude double taxation in cases not covered by this Treaty.
4. The competent authorities of the Contracting States may enter into direct contact for the purpose of an agreement within the meaning of the preceding paragraphs.
1. The competent authorities of the Contracting States shall exchange the information necessary for the implementation of this Treaty and the national laws of the Contracting States relating to the taxes to which this Treaty applies, provided that the taxation which they apply is in accordance with this Treaty. All information thus exchanged shall be classified and may be communicated only to the persons or authorities responsible for the assessment or collection of taxes covered by this Treaty.
2. The provisions of paragraph 1 shall in no case be interpreted as imposing an obligation on one of the Contracting States:
(a) to implement administrative measures which would be contrary to the laws, regulations or administrative practices of this or of the other Contracting State;
(b) provide information which could not be obtained by virtue of legislation or the normal administrative practice of that or other Contracting State; or
(c) provide information which would reveal business, business, industrial, commercial or professional secrecy or production process or information the disclosure of which would be contrary to public policy (ordre public).
The provisions of this Treaty shall not affect the tax privileges enjoyed by diplomatic and consular officials under the general rules of international law or under the provisions of specific agreements.
1. This Treaty will be ratified and instruments of ratification exchanged in Tokyo as soon as possible.
2. This Treaty shall enter into force on the 30th day following the replacement of the instruments of ratification and shall apply in both Contracting States to revenue for all fiscal years beginning on or after 1 January of the calendar year following that in which this Treaty enters into force.
This contract is for an indefinite period. However, each Contracting State may terminate it by giving written notice by diplomatic channels to the other Contracting State no later than 30 June of each calendar year after the expiry of a period of five years from the date on which the contract became valid. In such a case, the contract shall no longer apply in both Contracting States to income for all tax years beginning on or after 1 January of the calendar year following the year in which the notice was given.
They have signed this contract to prove the signature of the signature duly empowered to do so.
Dane in duplicate in Prague on 11 October 1977 in English.
For the Czechoslovak Socialist Republic:
František Hájek v. r.
For Japan:
Fumihiko Suzuki v. r.
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Regulation Information
| Citation | Decree of the Minister for Foreign Affairs No. 46 / 1979 Coll., on the Treaty between the Czechoslovak Socialist Republic and Japan on the avoidance of double taxation in the field of income taxes |
|---|---|
| Regulation Type | - |
| Author | - |
| Collection | Code of Laws |
| Date of Promulgation | 28.04.1979 |
|---|---|
| Effective from | 25.11.1978 |
| Effective until | - |
| Status | Valid |
The regulation text is for informational purposes only.
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