Communication from the Ministry of Foreign Affairs No. 482 / 2024 Coll.
Communication from the Ministry of Foreign Affairs on the Treaty between the Czech Republic and the Republic of Rwanda on the avoidance of double taxation in the field of income taxes and on the prevention of tax evasion and avoidance
Valid
International Treaty
Effective from 30.10.2024
Text versions:
30.12.2024
Zobrazeno prvních 200 z celkem 269 ustanovení tohoto předpisu.
Zobrazit celý předpis →
Pro stažení celého znění použijte tlačítko Stáhnout výše.
482
COMMUNICATION
Ministry of Foreign Affairs
on the conclusion of a Treaty between the Czech Republic and the Republic of Rwanda on the avoidance of double taxation in the field of income taxes and on the prevention of tax evasion and avoidance
The Ministry of Foreign Affairs announces that on 2 May 2023 a Treaty was signed in Kigali between the Czech Republic and the Republic of Rwanda to prevent double taxation in the field of income tax and to prevent tax evasion and avoidance.
The Parliament of the Czech Republic agreed to the Treaty and the President of the Republic ratified the Treaty.
The Treaty entered into force on 30 October 2024 pursuant to Article 27 thereof and its provisions shall be implemented in accordance with points (a) and (b) of that Article.
The English version of the Treaty and its translation into the Czech language are announced simultaneously.
Minister:
z. JUDr. Smolek, Ph.D., LL.M., v. r.
Chief Director of Legal and Consular Section
Příloha č. 1
Annex No 1
Text of the international treaty in the Czech language / Translation of international contract into Czech language
S M L O U V A
INTERI
CZECH REPUBLIC
A
RWAND REPUBLIC
ON THE TERMINATION OF DOUGH REVENUE
_
AND THE IMPLEMENTATION OF THE TAX EFFORT AND EXTENSION OF TAXATION OBLIGATIONS
THE CZECH REPUBLIC AND THE RWAND REPUBLIC,
Desiring to further develop their economic relations and strengthen their cooperation in tax matters,
intending to conclude a double taxation contract in the field of income taxes, without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through arrangements called "treaty-shopping 'aimed at obtaining the concessions provided for in this Treaty, in the indirect benefit of residents of third States or jurisdictions),
agree as follows:
Article 1
PERSONS CONCERNING THE TREATY
This Agreement shall apply to persons resident in one or both Contracting States.
Article 2
TAXES TO WHICH THE TREATY IS RELATING
1. This Agreement shall apply to income taxes levied on behalf of each of the Contracting States or its lower administrative departments or local authorities, whatever the method of collection.
2. All taxes levied on total income or on parts of income, including taxes on profits from the disposal of movable or immovable property, as well as taxes on total wages or salaries paid by undertakings, shall be regarded as income taxes.
3. The current taxes to which the Treaty applies are in particular:
(a) in Rwanda:
(i) personal income tax;
(ii) company income tax;
(b) in the Czech Republic:
(i) income tax on natural persons;
(ii) corporation tax.
4. The Treaty will also apply to any tax of the same or essentially similar kind which will be imposed after the date of signature of the Treaty in addition to or instead of the current taxes. The competent authorities of the Contracting States shall communicate to each other any substantial changes made to their respective tax laws.
Article 3
GENERAL DEFINITIONS
1. For the purposes of this Treaty, unless the link requires a different interpretation:
(a) the term "Rwanda" refers to the Republic of Rwanda and, where used in geographical importance, covers the whole territory, lakes and any other area in lakes and airspace where Rwanda may exercise sovereign rights or jurisdiction in accordance with international law;
(b) the term "Czech Republic" refers to the territory of the Czech Republic in which, under Czech law and in accordance with international law, the sovereign rights of the Czech Republic are exercised;
(c) the terms "one Contracting State" and "the other Contracting State" indicate, according to the context, the Czech Republic or Rwanda;
(d) the term "person" includes a natural person, a company and any other association of persons;
(e) the term "company" refers to any legal person or any rightholder regarded as a legal person for taxation purposes;
(f) the term "undertaking" refers to the pursuit of any activity;
(g) the terms "undertaking of one Contracting State" and "undertaking of the other Contracting State" indicate, according to the context, an undertaking operated by a resident of one Contracting State and an undertaking operated by a resident of the other Contracting State;
(h) the term "international transport" shall mean any transport by ship or aircraft operated by an undertaking of one Contracting State, except where the ship is operated or the aircraft is operated only between points in the other Contracting State;
(i) the term "competent authority" shall mean:
(i) in Rwanda, the Minister responsible for Finance or an authorised representative of that Minister;
(ii) in the Czech Republic, the Minister of Finance or an authorised representative of that Minister;
(j) the term "national" means:
(i) any natural person who is a national citizen of a Contracting State;
(ii) any legal person or association established or established under the legislation in force in a Contracting State;
(k) the term "activity" includes, but is not limited to, the pursuit of a free profession and other activities of an independent nature.
2. With regard to the implementation of the provisions of the Treaty at any time by any of the Contracting States, any term which is not defined therein, unless the link requires a different interpretation, shall have the meaning which it has at that time under the legislation of that State for the purposes of the taxes to which the Treaty applies, and any meaning under the tax laws of that State shall prevail over that term under other legislation of that State.
Article 4
RESIDENT
1. For the purposes of this Treaty, the term "resident of a Contracting State" shall mean any person who, under the legislation of that State, is subject to taxation in that State on account of his residence, permanent residence, place of establishment, place of main management or any other similar criterion, and shall also include that State or any lower administrative department or local authority of that State. However, this term does not include any person subject to taxation in that State solely because of income from resources in that State.
2. Where, pursuant to paragraph 1, a natural person is resident in both Contracting States, his status shall be determined as follows:
(a) that person shall be deemed to be resident only in the State in which he has a permanent flat; where that person has a permanent residence in both States, he shall be considered as resident only to the State for which he has closer personal and economic relations (centre of life interests);
(b) if it cannot be determined in which State the person has a centre of his or her life interests, or if he or she does not have a permanent residence in any State, he or she shall be considered as resident only in the State in which he or she normally resides;
(c) where that person normally resides in both States or in none of them, he shall be considered as resident only to the State of which he is a national;
(d) where that person is a national of both States or none of them, the competent authorities of the Contracting States shall amend the matter by mutual agreement.
3. Where a person, other than a natural person, is resident in both Contracting States pursuant to paragraph 1, the competent authorities of the Contracting States shall endeavour, by common accord, to designate a Contracting State which, for the purposes of the Treaty, is deemed to be resident, taking into account the place of its principal management, the place where it was established or otherwise legally established, and any other relevant factors. If such an agreement is not found, that person shall not be entitled to any tax relief or tax exemption provided for or provided for by this Treaty.
Article 5
STANDING OPERATIONS
(1) For the purposes of this Treaty, the term "permanent establishment" shall mean a permanent place of business through which the business of the undertaking is to be carried out in whole or in part.
2. the term "permanent establishment" includes in particular:
(a) the place of management;
(b) the plant;
(c) an office;
(d) the factory;
(e) workshop;
(f) storage;
(g) a farm, plantation or other place where agricultural, forestry or similar activities are carried out;
(h) place of sale.
3. the term "permanent establishment" also covers:
(a) construction sites, construction, assembly or installation projects, or any supervision linked thereto, but only if such construction sites, projects or surveillance lasts for more than six months;
(b) the provision of services, including consultancy or management services, by an undertaking of one contracting State or through staff or other personnel hired by the undertaking for that purpose, but only if the activities of that nature persist in the territory of the other contracting State for one or more periods exceeding six months in total in any 12-month period.
4. For the purposes of paragraph 3, activities carried out by an undertaking associated with a second undertaking shall be regarded as activities carried out by an undertaking with which the undertaking is associated if the activity in question:
(a) are essentially the same as the activities carried out there by the latter undertaking; and
(b) relate to the same project or operation;
except where such activities are carried out at the same time. For the purposes of this paragraph, undertakings shall be considered to be combined if the undertaking participates, directly or indirectly, in the management, control or capital of the other undertaking, or the same persons participate, directly or indirectly, in the management, control or capital of both undertakings.
5. Notwithstanding the previous provisions of this Article, the term "permanent establishment 'shall not include:
(a) an establishment which is used only for the purpose of storing or issuing goods belonging to an undertaking;
(b) the supply of goods belonging to an undertaking which is maintained only for the purpose of storage or display;
(c) a stock of goods belonging to an undertaking which is maintained only for the purpose of processing by another undertaking;
(d) a permanent place of activity which shall be maintained only for the purpose of purchasing goods or collecting information for the undertaking;
(e) a permanent place of activity which shall be maintained only for the purpose of carrying out any other activity for the undertaking;
(f) a permanent place of activity which shall be maintained only for the pursuit of any combination of the activities referred to in (a) to (e);
where such an activity or, in the case of point (f), the overall activity of a permanent place of activity is of a preparatory or auxiliary nature.
6. Where, notwithstanding the provisions of paragraphs 1 and 2, a person - other than an independent representative to whom paragraph 8 applies - acts on the behalf of an undertaking in a Contracting State and has and normally has the power 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 5, which, if carried out through a permanent place of business, would not be based on that permanent establishment in accordance with the provisions of this paragraph.
7. Notwithstanding the previous provisions of this Article, the insurance undertaking of one Contracting State shall, in the absence of a reinsurance activity, be deemed to have a permanent establishment in the other Contracting State where it collects insurance premiums in the territory of that other State or insure the risks that are present there through a person other than an independent representative to whom paragraph 8 applies.
8. An undertaking in one Contracting State shall not be considered to have a permanent establishment in the other Contracting State only because it carries out its business in that other State through a broker, a general agent or any other independent agent, where such persons act in the course of their proper activities. However, where the activities of such a representative are wholly or almost entirely devoted to the interests of that undertaking and other undertakings which are controlled by it or which have an interest in its control, that representative shall not be considered as independent within the meaning of this paragraph.
9. The fact that a company which is a resident of a Contracting State controls a company or is controlled by a company which is a resident of a second Contracting State or which carries out its activities in that other State (whether through a permanent establishment or otherwise) does not in itself constitute a permanent establishment of any other company.
Article 6
REVENUE FROM IMMOVABLE PROPERTY
1. Revenue received by a resident of one Contracting State from immovable property (including agricultural or forestry income) located in the other Contracting State may be taxed in that other State.
2. The term "immovable property" shall have such meaning as it may have under the law of the Contracting State in which the property is located. The term covers, in any case, real estate accessories, live and dead inventories used in agriculture and forestry, rights to which the provisions of civil law applicable to land, the right to use real estate and the right to variable or fixed payments for mining or to be authorised to mine mineral deposits, springs and other natural resources apply. Ships and aircraft shall not be considered property.
3. Paragraph 1 shall apply to revenue received from direct use, hire or any other use of immovable property.
4. The provisions of paragraphs 1 and 3 shall also apply to income from the company's immovable property.
Article 7
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 the other State, but only to the extent that they are attributable to:
(a) this permanent establishment; or
(b) sales of goods in that other State which are of the same or similar type as goods sold through that permanent establishment.
2. Where an undertaking of a Contracting State carries on its activities in the other Contracting State through a permanent establishment situated there, it shall be attributed, subject to paragraph 3, to each Contracting State of that permanent establishment, the profits which it could have achieved had it been engaged as a separate undertaking in the same or similar activities under the same or similar conditions and been wholly independent in contact with the undertaking of which it is a permanent establishment.
3. In determining the profits of a permanent establishment, it shall be permitted to deduct the costs incurred for the purpose of the activity of a permanent establishment, including management costs and general administrative expenses thus incurred, whether they arise in the Contracting State in which the permanent establishment is located or elsewhere. However, such deduction shall not be authorised for amounts, if any, paid (other than against the reimbursement of actual expenditure) by the permanent head office of the undertaking or any other office in the form of royalties, fees or other similar payments, in return for the use of patents or other rights or in the form of commission for special services provided or for management services, or, except in the case of a bank undertaking, in the form of interest on money lent to a permanent establishment. Similarly, when determining the profits of a permanent establishment, the amounts charged (other than against the reimbursement of actual expenditure) by the permanent head office of an undertaking or any other office in the form of royalties, fees or other similar payments shall not be taken into account in compensation for the use of patents or other rights or in the form of commission for specific services provided or for management services or, except in the case of a banking undertaking, in the form of interest on the money lent to the head office of the undertaking or any other office of that undertaking.
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, nothing in paragraph 2 shall preclude that Contracting 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 added to a permanent establishment shall be determined in the same way each year, unless there are sufficient grounds for otherwise.
7. Where profits include parts of income which are dealt with separately in other Articles of this Treaty, the provisions of those Articles shall be without prejudice to the provisions of this Article.
Article 8
INTERNATIONAL TRANSPORT
1. The profits received by the undertaking of a Contracting State from the operation of ships or aircraft in international transport shall be subject to taxation only in that State.
2. For the purposes of this Article, and notwithstanding the provisions of Article 12, profits from the operation of ships or aircraft in international transport shall include:
(a) profits from the hire of ships or aircraft without crew; and
(b) profits from the use, maintenance or hire of containers (including trailers and associated container transport equipment) used for the transport of goods;
where such lease or such use, maintenance or lease, whichever case is concerned, is accidental in relation to the operation of ships or aircraft in international transport.
3. Paragraph 1 shall also apply to profits arising from participation in a pool, joint operation or an international operational organisation.
Article 9
ASSOCIATED 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 participate, directly or indirectly, in the management, control or capital of an undertaking of one Contracting State and of an undertaking of the other Contracting State;
and if, in such cases, both undertakings are bound in their commercial or financial relations by the conditions which they have negotiated or imposed on them and which differ from those which would have been negotiated between independent undertakings, any profits which, if not for those conditions, would have been achieved by one of the undertakings but have not been achieved, may be included in the profits of that undertaking and subsequently taxed.
2. If one contracting State includes in the profits of the undertaking of that State - and subsequently of the tax - the profits which the undertaking of the other contracting State has been taxed in that other State and the profits thus included are profits which would have been realised by the undertaking of the first State if the conditions negotiated between the two undertakings were such as would have been agreed between the independent undertakings, the latter State shall adjust accordingly the amount of tax levied on those profits. The other provisions of this Treaty shall be taken into account in determining such an adjustment and, if necessary, the competent authorities of the Contracting States shall consult each other for that purpose.
3. The provisions of paragraph 2 shall not apply where judicial, administrative or other legal proceedings have led to a final decision that, by virtue of the conduct which has given rise to the adjustment of profits referred to in paragraph 1, one of the undertakings concerned is subject to a penalty relating to fraud, gross negligence or wilful negligence.
Article 10
DIVIDENDS
1. Dividends paid by a company resident in one Contracting State, resident in the other Contracting State, may be taxed in that other State.
2. Dividends paid by a company that is resident in one Contracting State may, however, also be taxed in that State under the legislation of that State, but if the beneficial owner of dividends is resident in the other Contracting State, the tax thus imposed shall not exceed 10 per cent of the gross amount of dividends.
This paragraph shall not affect the taxation of the profits of the company on which dividends are paid.
3. The term "dividends" used in this Article refers to income from shares or other rights (with the exception of receivables) with a profit share, as well as other income which is subject to the same tax regime as income from shares under the legislation of the Contracting State of which the company which differentiates profits or makes payments is resident.
4. The provisions of paragraphs 1 and 2 shall not apply where the beneficial owner of dividends resident in one Contracting State carries out his activity in the other Contracting State of which the dividend company is resident through a permanent establishment situated there and where the participation for which the dividends are paid is actually linked to that permanent establishment. In that case, the provisions of Article 7 shall apply.
5. Where a company which is resident in one Contracting State achieves profits or income from the other Contracting State, that other State may not tax dividends paid by the company unless such dividends are paid to the resident of that other State or that the participation for which dividends are paid actually relates to a permanent establishment located in that other State or to subject the company's undistributed profits to the tax on undistributed profits, even if the dividends paid or earnings distributed are wholly or partly derived from profits or income having a source in that other State.
Article 11
INTEREST
1. Interest having a source in one Contracting State and paid to the resident of the other Contracting State may be taxed in that other State.
2. However, interest having a source in one Contracting State may also be taxed in that State under the legislation of that State, but if the beneficial owner of interest is resident in the other Contracting State, the tax thus imposed shall not exceed 10 per cent of the gross amount of interest.
3. Interest having a source in one Contracting State shall be subject to taxation, irrespective of the provisions of paragraph 2, only in the other Contracting State where such interest is actually owned by:
(a) the government of the other State, including any lower administrative department or local authority of that State, the central bank of the other State or any institution owned or controlled by that Government, where the purpose of such an institution is to promote investment or export;
(b) resident of a second State in respect of any loan or credit guaranteed or guaranteed by the Government of a second State, including any lower administrative department or local office of that State, the central bank of the second State or any financial institution owned or controlled by that Government, where the purpose of such an institution is to promote investment or export.
4. The term "interest 'used in this Article refers to income on claims of any kind, whether secured or not, or not secured by a lien on immovable property and having or not having the right to participate in the debtor's profits, and in particular, income from government securities and income from bonds or bonds, including premiums and winnings related to such securities, bonds or bonds. Penalties imposed for late payment shall not be considered as interest for the purposes of this Article. The term" interest' shall not include any part of income which is considered a dividend under the provisions of Article 10 (3).
5. The provisions of paragraphs 1, 2 and 3 shall not apply where the beneficial owner of interest resident in one Contracting State carries out his activity in the other Contracting State in which the source is situated through a permanent establishment situated there and where the claim on which the interest is paid is indeed linked to that permanent establishment. In that case, the provisions of Article 7 shall apply.
6. Interest shall have a source in a Contracting State if the payer is a resident of that State. However, if the interest payer, whether or not he is a resident of a Contracting State, has a permanent establishment in the Contracting State, in conjunction with the debt on which the interest is paid, and that interest is payable on such a permanent establishment, that interest shall have a source in the State in which the permanent establishment is situated.
7. If the amount of interest relating to the claim on which it is paid exceeds, due to the special relationship between the payer and the beneficial owner or between both of them and any other person, the amount which the payer would have agreed with the beneficial owner if it had not been for such a relationship, the provisions of this Article shall apply only to that latter amount. In this case, the amount of payments exceeding it shall be taxed in accordance with the laws of each Contracting State, taking into account the other provisions of this Treaty.
Article 12
LICENCES AND TECHNICAL SERVICES CHARGES
1. Licensing fees and fees for technical services having a source in one Contracting State and paid to the resident of the other Contracting State may be taxed in that other State.
2. However, licence fees and fees for technical services having a source in one Contracting State may also be taxed in that State under the legislation of that State, but if the beneficial owner of the licence or technical service charges is resident in the other Contracting State, the tax thus imposed shall not exceed 10 per cent of the gross amount of the licence or technical service charges.
3.
(a) The term "licence fees" used in this Article shall refer to payments of any kind received as compensation for use or as the right to use any copyright for the work of literary, artistic or scientific, including cinematographic films, or films, tapes and other means of visual or audible reproduction, any patent, trademark, design or model, plan, secret formula or procedure, or any industrial, commercial or scientific establishment, or for information which relates to experience acquired in the field of industrial, commercial or scientific.
(b) The term "fees for technical services" used in this Article shall refer to any payment for any service of a technical, advisory or managerial nature, but shall not include payments for services referred to in Articles 8, 14, 15, 16 and 18. The term also does not include payments made by a natural person for services rendered for the purposes of the personal needs of a natural person and payments for teaching by educational institutions or educational institutions.
4. The provisions of paragraphs 1 and 2 shall not apply where the beneficial owner of the licence fees or fees for technical services resident in one Contracting State carries out his activity in the other Contracting State in which the licence fees or fees for technical services are provided by a source, through a permanent establishment situated there, and where the law, property or service giving rise to royalties or fees for technical services is actually linked to that permanent establishment. In that case, the provisions of Article 7 shall apply.
5. Licensing and technical service charges shall have a source in the Contracting State if the payer is a resident of that State. However, where a licence fee or technical service fee payer, whether or not resident in a Contracting State, has a permanent establishment in a Contracting State, in conjunction with which a licence fee or technical service fee has been required, and such licence or technical service charges are liable to such a permanent establishment, such licence or technical service charges shall have a source in the State in which the permanent establishment is located.
6. Where the amount of royalties or fees for technical services relating to the use, right, information or service for which they are paid exceeds, as a result of special relations between the payer and the beneficial owner, or between both of them and any other person, the amount which the payer would have agreed with the beneficial owner if it had not been for such relations, the provisions of this Article shall apply only to that latter amount. In this case, the amount of payments exceeding it shall be taxed in accordance with the laws of each Contracting State, taking into account the other provisions of this Treaty.
Article 13
OWN FUNDS PROFIT
(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 State.
(2) Profit from the disposal of 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, including the proceeds from the disposal of such permanent establishment (alone or together with the whole undertaking), may be taxed in that other State.
3. Profit from the disposal of assets which are part of the operating assets of an undertaking of a Contracting State and which remains from ships or aircraft operated by that undertaking in international transport or from movable assets used to operate such ships or aircraft shall be subject to taxation only in that State.
(4) The profits received by a resident of one Contracting State from the disposal of shares or other shares in a company resident in the other Contracting State may be taxed in that other State.
5. Profit from the disposal of any assets other than those referred to in the preceding paragraphs of this Article shall be subject to taxation only in the Contracting State of residence of the transferee.
Article 14
REVENUE FROM 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 15, 17 and 18, 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 may be taxed in that other State.
2. The remuneration received by a resident of a Contracting State on the grounds of employment in the other Contracting State shall, notwithstanding the provisions of paragraph 1, be subject to taxation only in the former State if all the following conditions are met:
(a) the beneficiary shall be employed in the other State for one or more periods not exceeding 183 days in total in any 12-month period beginning or ending in the relevant tax year; and
(b) the remuneration is paid by the employer or by an employer who is not resident in the other Contracting State; and
(c) the remuneration shall not be borne by a permanent establishment held by the employer in the second Contracting State.
3. The following days shall be included in the calculation of the period referred to in paragraph 2 (a):
(a) all days of physical presence, including days of arrival and departure; and
(b) days spent outside the State of activities such as Saturdays and Sundays, public holidays, holidays and business trips directly linked to the employment of the beneficiary in that State, after which the activity in that State continued.
4. The term "employer" referred to in paragraph 2 (b) shall refer to a person who has the right to work done and who bears responsibility and the risk associated with carrying out the work.
5. Notwithstanding the previous provisions of this Article, remuneration received on account of employment carried on board a ship or aircraft operating or operating in international transport by an undertaking of a Contracting State shall be subject to taxation only in that State.
Article 15
TANTIES
Tantiéms and similar remuneration received by a resident of one Contracting State as a member of the Management Board or any other similar body of a company resident of another Contracting State may be taxed in that other State.
Article 16
Artists and SPORTS
1. Revenue received by a resident of a Contracting State as an artist acting in public, such as a theatre, film, radio or television artist or musician or as an athlete from such activities personally carried out in the other Contracting State may be taxed in that other State regardless of the provisions of Articles 7 and 14.
2. Where the income from activities personally carried out by an artist or athlete is not derived from artists or athletes, but from other persons, such income may be taxed, irrespective of the provisions of Articles 7 and 14, in the Contracting State in which the activities of an artist or athlete are carried out.
3. The provisions of paragraphs 1 and 2 shall not apply to revenue received from activities carried out in one Contracting State by an artist or an athlete resident in the other Contracting State where a visit to the former State is financed entirely from public funds of the other State or its lower administrative departments or local authorities. In such cases, income is subject to taxation only in the State of residence of the artist or athlete.
Article 17
PENSION AND OTHER SIMILAR PAYMENTS
Pensions and other similar salaries paid by a resident of a Contracting State on account of former employment shall be subject to taxation only in that State, subject to the provisions of Article 18 (2).
Article 18
PUBLIC FUNCTIONS
Sign in for notes, favorites and notifications
Regulation Information
| Citation | Communication from the Ministry of Foreign Affairs No. 482 / 2024 Coll., on the Agreement between the Czech Republic and the Republic of Rwanda on the avoidance of double taxation in the field of income taxes and on the prevention of tax evasion and avoidance |
|---|---|
| Regulation Type | International Treaty |
| Author | - |
| Collection | Code of Laws |
| Date of Promulgation | 30.12.2024 |
|---|---|
| Effective from | 30.10.2024 |
| Effective until | - |
| Status | Valid |
The regulation text is for informational purposes only.
Comments 0