Communication from the Ministry of Foreign Affairs No. 64 / 1994 Coll.

Communication from the Ministry of Foreign Affairs supplementing Communication No. 31 / 1994 Coll., on the Treaty between the Government of the Czech Republic and the Government of the Republic of Poland on the avoidance of double taxation in the field of income and property taxes signed in Warsaw on 24 June 1993

Valid Effective from 20.12.1993
Text versions: 31.03.1994
64
COMMUNICATION
Ministry of Foreign Affairs,
supplementing Communication No 31 / 1994 Coll., on the Treaty between the Government of the Czech Republic and the Government of the Republic of Poland on the avoidance of double taxation in the field of income and property taxes signed in Warsaw on 24 June 1993
The Ministry of Foreign Affairs complements Communication No. 31 / 1994 Coll., which published the Czech version of the Treaty between the Government of the Czech Republic and the Government of the Republic of Poland on the avoidance of double taxation in the field of income and property taxes signed in Warsaw on 24 June 1993. At the same time as the Treaty, the Protocol to the Treaty between the Government of the Czech Republic and the Government of the Republic of Poland on the avoidance of double taxation in the field of income and property taxes was signed in Warsaw on 24 June 1993.
According to paragraph 1: From the date of entry into force of this Treaty, i.e. 20 December 1993, the Czech Republic and the Republic of Poland shall cease to apply the following multilateral agreements in their relations:
Treaty on the prevention of double taxation of income and property of natural persons, signed in Miskovci on 27 May 1977, published under No 30 / 1979 Coll.,
and
Treaty on the prevention of double taxation of corporate income and property, signed at Ulanbatar on 19 May 1978, published under No 49 / 1979 Coll.
Czech version The Protocol shall be published simultaneously. The English version of the Protocol, which is relevant for its interpretation, can be consulted by the Ministry of Foreign Affairs and the Ministry of Finance.

PROTOCOL
to the Treaty between the Government of the Czech Republic and the Government of the Republic of Poland on the avoidance of double taxation in the field of income and property taxes
When signing the Treaty between the Government of the Czech Republic and the Government of the Republic of Poland on the avoidance of double taxation in the field of income and property taxes, the signatures, duly empowered by their governments, were agreed as follows:
1. From the date of entry into force of this Treaty, the Czech Republic and the Republic of Poland shall cease to apply, in their mutual relations, a multilateral agreement on the avoidance of double taxation in the field of income taxes and on the property of natural persons signed in Mishkovci on 27 May 1977 and a multilateral agreement on the avoidance of double taxation in the field of income taxes and corporate property signed in Ulanbátar on 19 May 1978.
2. The calculation of the period referred to in Article 5 (3) of this Treaty shall begin on 1 January 1994.
3. The construction site or activities referred to in Article 5 (3) of this Treaty relating to contracts concluded before 1 June 1992 shall not be considered as a permanent establishment if their duration does not exceed 18 months after 1 January 1993.
4. Remuneration paid to a resident of a Contracting State in respect of the activities referred to in paragraph 3 of this Protocol shall not be subject to taxation in the other Contracting State in which such activities are carried out, provided that the duration of such activities does not exceed 18 months after 1 January 1993. In this respect, Article 15 (2) of this Treaty shall not apply.
This Protocol shall form an integral part of the abovementioned Treaty.
They signed this protocol to prove the signature, duly empowered to do so.
Done in duplicate in Warsaw on 24 June 1993 in the Czech, Polish and English languages, all texts authentic. In the event of any differences in interpretation, the English text will be decisive.
For the Government
Czech Republic:
J. Strástský v. r.
For the Government
Republic of Poland:
J. Osiatinski v. r.

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Regulation Information

CitationCommunication from the Ministry of Foreign Affairs No. 64 / 1994 Coll., supplementing Communication No. 31 / 1994 Coll., on the Treaty between the Government of the Czech Republic and the Government of the Republic of Poland on the avoidance of double taxation in the field of income and property taxes signed in Warsaw on 24 June 1993
Regulation Type-
Author-
CollectionCode of Laws
Date of Promulgation31.03.1994
Effective from20.12.1993
Effective until-
Status Valid
The regulation text is for informational purposes only.
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