Decree of the Minister for Foreign Affairs No. 77 / 1987 Coll.
Decree of the Minister for Foreign Affairs on the Treaty between the Government of the Czechoslovak Socialist Republic and the Government of India on the avoidance of double taxation and the prevention of tax evasion in the field of income taxes
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Effective from 13.03.1987
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77
DECLARATION
Minister for Foreign Affairs
of 13 July 1987
on the Treaty between the Government of the Czechoslovak Socialist Republic and the Government of India on the avoidance of double taxation and the prevention of tax evasion in the field of income taxes
On 27 January 1986, a Treaty was signed in Delhi between the Government of the Czechoslovak Socialist Republic and the Government of India on the avoidance of double taxation and the prevention of tax evasion in the field of income taxes and the Protocol thereto.
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 13 March 1987 pursuant to Article 28 thereof.
The Czech translation of the Treaty is announced simultaneously.
Minister:
Ing. Chupek v. r.
TREATY
between the Government of the Czechoslovak Socialist Republic and the Government of India 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 India, wishing to conclude a treaty to avoid double taxation and prevent tax evasion in the field of income taxes,
they have agreed as follows:
PERSONS CONCERNING THE TREATY
This Treaty shall apply to persons residing or having their registered office in one or both Contracting States.
TAXES TO WHICH THE TREATY IS RELATING
1. the taxes to which this Treaty applies are:
(a) India:
(1) Income tax with an increase under the Income Tax Act No 43 of 1961;
(2) Additional tax pursuant to the Law on Additional Tax on Profit of Companies No 7 of 1964 (hereinafter referred to as "Indian Tax");
(b) in Czechoslovakia:
(1) profit payment and profit tax,
(2) payroll tax,
(3) income tax on literary and artistic activities,
(4) Agricultural tax,
(5) a public income tax; and
(6) Home tax
(hereinafter referred to as "Czechoslovak Tax ').
2. The contract shall also cover all identical or substantially similar taxes to be imposed by the Contracting States following the signature of this Treaty, in addition to or in place of the taxes referred to in paragraph 1 of this Article.
3. At the end of each year, the competent authorities of the Contracting States shall notify each other of any significant changes made to their respective tax laws which are the subject of this Treaty and shall send copies of the relevant laws and regulations.
GENERAL DEFINITIONS
1. In this Treaty, unless the link requires a different interpretation:
(a) the term "India" refers to the territory of India and includes coastal waters and airspace above them and all other sea zones over which India exercises sovereign rights and other rights and powers under Indian law and in accordance with international law and the United Nations Convention on the Law of the Sea;
(b) the term "Czechoslovakia" refers to the Czechoslovak Socialist Republic;
(c) the terms "one Contracting State" and "the other Contracting State" refer to India or Czechoslovakia as required by the connection;
(d) the term "tax" means an Indian tax or a Czechoslovak tax, as the context requires;
(e) the term "person" shall have meaning as determined by the tax laws in force in the relevant Contracting States;
(f) the term "company" refers to any legal person or any substance considered to be a company under the tax laws of the relevant Contracting States;
(g) the terms "undertaking of one Contracting State" and "undertaking of the other Contracting State" indicate, as appropriate, an undertaking operated by a person residing or having its registered office in one Contracting State and an undertaking operated by a person residing or having its registered office in the other Contracting State;
(h) in the case of India, the term "competent authority" refers to the Ministry of Finance of the Central Government (State Revenue Department) and the Minister of Finance of the Czechoslovak Socialist Republic or his duly authorised representative.
2. Any term which is not otherwise defined shall have the meaning, under the laws in force in that Contracting State, which governs taxes which are the subject of this Treaty for the application of the provisions of this Treaty, unless the link requires a different interpretation.
TAXABLE HOME
1. For the purposes of this Treaty, the term "resident or domiciled in a Contracting State 'shall mean any person who, under the tax rules of that Contracting State, is considered to be resident in that Contracting State or, where appropriate, having its registered office in that Contracting State.
2. Where, pursuant to paragraph 1, a natural person resides in both Contracting States, his residence for the purposes of this Treaty shall be determined in accordance with the following rules:
(a) It shall be assumed that this person is resident in the Contracting State in which he is resident. If it has a permanent residence in both Contracting States, it will be assumed that it is resident in the Contracting State with which its personal and economic relations are the narrowest (hereinafter referred to as "the Centre of Life Interests').
(b) If the Contracting State in which the person has a life-interest centre cannot be designated or if he does not have a permanent residence in either of the two Contracting States, he shall be presumed to reside in the Contracting State in which he normally resides.
(c) If that person is usually present in both Contracting States or if he is not normally present in any of them, he shall be presumed to reside in the Contracting State of which he is a national.
(d) If that person is a national citizen of both Contracting States or if he is not a national citizen of any of them, the competent authorities of the Contracting States shall decide by mutual agreement.
3. Where a person other than a natural person has its registered office in both Contracting States pursuant to paragraph 1, it shall be assumed to have its registered office in the Contracting State in which the place of its effective management is situated.
STANDING OPERATIONS
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:
(a) place of management;
(b) race;
(c) an office;
(d) the factory;
(e) workshop or warehouse;
(f) mine, quarry, oil site or other site of extraction of natural resources;
(g) construction sites, installation or supervision of them, where such construction sites, assembly or supervision lasts for more than 6 months or where such assembly or supervision related to the sale of machinery or equipment does not last for more than 6 months, but costs to be paid for installation or supervision exceed 10% of the selling price of machinery or equipment.
3. the term "permanent establishment" does not cover:
(a) an establishment which is used only for the purpose of storing or issuing goods belonging to an undertaking;
(b) a stock of goods belonging to an undertaking which is kept only for storage or display;
(c) a stock of goods belonging to an undertaking which is maintained only for the purpose of processing by the undertaking of the other Contracting State;
(d) permanent business equipment which is maintained only for the purpose of purchasing goods or collecting information for the undertaking;
(e) permanent business equipment which is maintained only for the purpose of advertising, providing information or scientific research where such activities are of only a preparatory or ancillary nature for the production or business of the undertaking. However, this provision shall not apply where an undertaking maintains a permanent establishment for business in the other Contracting State for purposes other than those referred to in this paragraph.
4. A person acting in one Contracting State for an undertaking or on behalf of an undertaking of the other Contracting State - other than an independent representative to whom paragraph 5 applies - shall be regarded as a permanent establishment of that undertaking in the first Contracting State if:
(a) has and usually exercises a power of attorney in that Contracting State to act and conclude contracts on behalf of an undertaking, unless its activity is limited to purchases of goods for an undertaking; or
(b) normally keeps a stock of goods belonging to the undertaking from which it regularly supplies the goods on behalf of the undertaking in the first Contracting State; or
(c) it normally collects orders in the first Contracting State exclusively or almost exclusively for an undertaking or for an undertaking and other undertakings controlled by it or having a participation in it ensuring that they have the right to manage the undertaking.
5. It is not assumed that an undertaking in one Contracting State has a permanent establishment in the other Contracting State only because it carries out its business there through a broker, a general agent or another independent representative, if those persons act in the proper framework of their activities.
6. The fact that a company which has its registered office in one Contracting State controls a company or is controlled by a company which has its registered office in the other Contracting State or which carries on business in that other Contracting State (whether through a permanent establishment or otherwise) does not in itself make one of the two companies a permanent establishment of the other company.
7. It will be assumed that an undertaking of one Contracting State has a permanent establishment in the other Contracting State if it carries out an activity which remains from the provision of services by public performers (such as theatre, film, radio and television artists and musicians) or from athletes in that other Contracting State, unless the undertaking is directly or indirectly, wholly or substantially supported by public funds of the Government of the first State in conjunction with the provision of such services.
REVENUE FROM IMMOVABLE PROPERTY
1. The income from immovable property may be taxed only in the Contracting State in which such property is located.
2. the term "immovable property" shall be determined in accordance with the law and practice of the Contracting State in which the property is located. In any case, the term covers real estate accessories, whether live or dead inventory, used in agriculture and forestry, rights to which the provisions of civil land property law apply, the right to consume immovable property and the right to variable or fixed salaries, provided as compensation for mining or the right to mine mineral deposits, oil springs, quarries and other natural resources. Ships and aircraft shall not be considered immovable property.
3. The provisions of paragraph 1 shall apply to income arising 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 company's immovable property and to income from immovable property used to perform independent professional services.
INDUSTRIAL AND COMMERCIAL PROFIT
1. The profits of an undertaking of one Contracting State shall be subject to taxation only in that State if the undertaking does not operate in the other Contracting State through a permanent establishment situated there. Where an undertaking carries on such an activity, the profits of the undertaking may be taxed in that other State, but only to the extent that they can be attributed
(a) this permanent establishment;
(b) sales of goods in that other State where they are goods of the same or similar kind as those sold through that permanent establishment; or
(c) other activities carried out in that other State in so far as they are activities similar to or similar to those carried out through that permanent establishment.
2. Where an undertaking of a Contracting State carries on business in the other Contracting State through a permanent establishment situated there, it shall, subject to the provisions of paragraph 3 in each Contracting State of that State, be attributed to profits which it would expect to achieve if, as a separate undertaking, it performed the same or similar activities under the same or similar conditions and traded completely independently with the undertaking of which it is a permanent establishment. In any event, if the correct amount of profits to be added to a permanent establishment cannot be determined or if its determination causes exceptional difficulties, the profits to be attributed to a permanent establishment may be estimated in a reasonable manner.
3. In determining the profits of a permanent establishment, it is permitted to deduct the costs incurred for the operation of that permanent establishment, including management costs and general administrative expenses thus incurred, whether incurred in the State where the permanent establishment is located or not, in accordance with the provisions and reservations contained in the tax laws of that State. However, amounts which have been paid (other than as compensation for actual expenses) by the permanent management of an undertaking or by some other of its offices in the form of royalties, refunds or other similar salaries for the use of patents, know- how or other rights, or in the form of commission, other salaries for special services provided, for administration and management, or, in the case of a banking undertaking, 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 to be borne by the permanent establishment (otherwise than for actual expenses) by the management or any other office of the firm for royalties, compensation or other similar salaries for the use of patents, know- how or other rights, or by commission or other salaries for specific services provided, for administration and management, or, in the absence of a banking undertaking, in the form of interest on the money lent to the management or any other office of the firm.
4. The permanent establishment will not receive any profits because the permanent establishment only purchased goods for the undertaking.
(5) For the purposes of the preceding paragraphs, profits to be attributed to a permanent establishment shall be determined each year on the basis of the same method, unless there are serious and sufficient grounds for a different procedure.
6. 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.
AIR TRANSPORT
1. The income from the operation of aircraft by an undertaking of one Contracting State shall not be taxed in the other Contracting State unless the aircraft are used for transport wholly or principally between places situated in the other Contracting State.
2. Paragraph 1 shall apply mutatis mutandis to the participation of air transport undertakings in a pool of any kind.
3. Interest from funds directly linked to the operation of aircraft in international transport shall be considered as income from the operation of such aircraft for the purposes of paragraph 1.
ASSOCIATED UNDERTAKINGS
If
(a) the undertaking of one contracting State participates, directly or indirectly, in the management, management or capital of the undertaking of the other contracting State; or
(b) the same persons participate, directly or indirectly, in the management, management or capital of the undertaking of one Contracting State and of the undertaking of the other Contracting State,
and if, in one or both of the two undertakings in their commercial or financial relations, conditions have been negotiated or imposed on them which differ from those which would have been agreed between independent undertakings, profits which, without such conditions, would have been achieved by one of the undertakings but which had not been acquired for those conditions may be included in the profits of that undertaking and subsequently taxed.
DIVIDENDS
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 State.
2. However, such dividends may also be taxed in the Contracting State in which the company which pays them has its registered office, under the legislation of that State, but where the beneficiary is the beneficial owner of dividends, the tax thus imposed shall not exceed:
(a) 15% of the gross dividend amount where the beneficial owner of the dividends is a company which holds at least 25% of the shares in the dividend company;
(b) 25% of the gross dividend amount 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 refers to income from shares or other rights, unless they are claims linked to participation in profits, as well as income from other social rights which are subject to the same tax as income from shares under the laws of the State in which the company paying dividends is situated.
4. The provisions of paragraphs 1 and 2 shall not apply where the beneficial owner of dividends residing or having his registered office in a Contracting State is engaged in an industrial or commercial activity in the second Contracting State in which the company paying dividends has its registered office through a permanent establishment located there or provides, independently in that other State, personal services from a permanent base located there and where the ownership of the shares on the basis of which the dividends are paid is actually linked to such permanent establishment or permanent base. In that case, the provisions of Article 7 or Article 14 shall apply depending on the case.
5. Where a company having its registered office in one Contracting State achieves profits or income from the other Contracting State, that other State may not tax dividends paid by that company, unless it is dividends paid to a person resident in that other State or the ownership of shares on the basis of which dividends are paid, it is actually linked to a permanent establishment or permanent base located in that other State, or subject to the company's undistributed profits to the tax on the company's undistributed profits, even if the dividends paid or earnings retained in whole or in part of the profits or income derived from that other State.
INTEREST
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 State.
2. However, such interest may also be taxed in the Contracting State in which its source is located under the legislation of that State, but if the beneficiary is the beneficial owner of the interest, the tax thus imposed shall not exceed 15% of the gross amount of interest.
3. notwithstanding the provisions of paragraph 2,
(a) interest shall be exempt from taxation in the Contracting State in which their source is, provided that the beneficiary and the beneficial owner is:
(i) a government, a lower administrative department or a local authority of the other Contracting State; or
(ii) the central bank of the second contracting State;
(b) interest shall be exempt from taxation in the Contracting State in which their source is situated if the beneficial owner is the person residing or having his registered office in the second Contracting State who receives such interest in connection with a loan or loan granted or guaranteed:
(i) in the case of Czechoslovakia, the Czechoslovak Commercial Bank, where the interest is exclusively derived from export and import financing,
(ii) in the case of India, the Export-Import Bank of India (Exim Bank) if the interest is exclusively derived from export and import financing,
(iii) any institution of a Contracting State entrusted with public financing of foreign trade,
(iv) any other person, provided that the loan or loan has been approved by the Government of the first Contracting State.
4. The term "interest 'used in this Article refers to income on claims of any kind secured or not secured by a lien on immovable property, both providing or providing the right to participate in the debtor's profits, and in particular income on public bonds and bonds, including bonuses and winnings associated with those bonds and bonds. Penalties for late payment shall not be considered as interest for the purposes of this Article.
5. The provisions of paragraphs 1 and 2 shall not apply where the beneficial owner of interest residing or having his registered office in one Contracting State carries out an industrial or commercial activity in the other Contracting State in which the interest is received through a permanent establishment situated there or provides, independently in that other State, personal services from a permanent base situated there and where the claim on which interest is paid is actually linked to such a permanent establishment or permanent base. In that case, the provisions of Article 7 or Article 14 shall apply depending on the case.
6. Interest shall be assumed to have a source in one Contracting State where the payer is the latter himself, the lower administrative department or local office of that State or the person residing or having his registered office in that State. However, if the interest payer, whether residing or not in a Contracting State, has a permanent establishment or permanent base in a Contracting State in conjunction with which an obligation to pay interest has arisen and if such interest is due to that permanent establishment or permanent base, the source of such interest shall be assumed to be 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, is assessed, as a result of the special relationship existing between the payer and the beneficial owner of the interest or between the two and a third party, the amount that 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 part of the interest paid which exceeds that shall be subject to taxation under the legislation of each Contracting State, taking into account the other provisions of this Treaty.
LICENCES AND CHARGES FOR TECHNICAL SERVICES
1. Licensing fees and fees for technical services which have a source in one Contracting State and are paid to a person residing or having his registered office in the other Contracting State may be taxed in that other State.
2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which their source is located under the legislation of that State, but where the recipient is the beneficial owner of royalties or fees for technical services, the tax thus imposed shall not exceed 30% of the gross amount of royalties or fees for technical services.
3. The term "licence fees' used in this Article shall refer to the salaries of any kind received by way of compensation for use or the right to use any copyright to any literary, artistic or scientific work, including cinematographic films or films and radio or television tapes, any patent, trademark, model or model, plan, secret formula or procedure, or use or use of industrial, commercial or scientific equipment or for information relating to industrial, commercial or scientific experience.
4. The term "fees for technical services' used in this Article refers to salaries of any amount paid to persons other than the staff of the payer for services of a management, technical or advisory nature, including the provision of technical and other staff services.
5. The provisions of paragraphs 1 and 2 shall not apply where the beneficial owner of royalties or fees for technical services domiciled in or established in a Contracting State carries out in the second Contracting State in which the royalties or fees for technical services are provided by a source, industrial or commercial activity through a permanent establishment situated there, or provides, independently in that other State, personal services from a permanent base located there, and where the law, property or contract in respect of which the royalties or salaries for technical services are paid are actually linked to such a permanent establishment or permanent base. In that case, the provisions of Article 7 or Article 14 shall apply depending on the case.
6. Licensing fees and fees for technical services shall be presumed to have a source in one Contracting State where the payer is the latter himself, the lower administrative department or the local office of that Contracting State or the person residing or having his registered office in that State. However, where a person who pays royalties or salaries for technical services, whether or not he or she is domiciled in a Contracting State, has a permanent establishment or permanent base in a Contracting State, in conjunction with which an obligation has been made to pay royalties or salaries for technical services, and that permanent establishment or permanent base bears such royalties or fees for technical services, such royalties or fees for technical services shall be assumed to have a source in the State in which the permanent establishment or permanent base is located.
7. Where the amount of royalties or fees for technical services exceeds the amount which would have been paid 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 salaries exceeding it shall be subject to taxation under the legislation of each Contracting State, taking into account the other provisions of this Treaty.
OWN FUNDS PROFIT
(1) Profit realised by a person residing or having his registered office in 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. Proceeds from the disposal of movable property which is part of the operating property of a permanent establishment held by an undertaking of a Contracting State in the other Contracting State, or of movable property belonging to a permanent base which is owned by a person resident in one Contracting State in the other Contracting State for the provision of independent personal services, including profits from the disposal of such permanent establishment (on its own or together with the whole undertaking), or such permanent bases, may be taxed in that other State.
3. Profit from the disposal of ships or aircraft used in international transport or of movable property belonging to the operation of such ships or aircraft shall be subject to taxation only in the Contracting State in which the alien is resident or established.
4. Profit from the disposal of shares in the assets of a company whose assets remain, directly or indirectly, mainly of immovable property located in a Contracting State may be taxed in that State.
5. Profit from the disposal of shares in companies other than those referred to in paragraph 4 shall be taxed in the Contracting State in which the company has its registered office.
6. Profit from the disposal of assets other than those referred to in paragraphs 1, 2, 3, 4 and 5 shall be subject to taxation only in the Contracting State in which the transferee resides or resides.
INDEPENDENT PERSONAL SERVICES
1. Revenue received by a natural person residing in a Contracting State for the provision of professional services or for other independent activities of a similar nature shall be subject to taxation only in that State; in the following cases, such income may also be taxed in the second 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 such a case, only part of the income attributable to that permanent base may be taxed in that other State; or
(b) if his stay in that other Contracting State lasts for a total period of 90 or more days in the relevant "earlier year" or in the "income year" as appropriate; in this case, only part of the income generated by the activities carried out in that other State may be taxed in that other State.
2. The term "professional services" includes the independent activities of scientific, literary, artistic, educational or teaching doctors, surgeons, lawyers, engineers, architects, dentists and accountants.
RELATED PERSONAL SERVICES
1. Wages, salaries and other similar remuneration which a person residing in one Contracting State receives from employment shall be subject to taxation in that State only, subject to the provisions of Articles 16, 17, 18, 19, 20 and 21, 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 that other State.
2. Remuneration which a person residing in one Contracting State receives from employment in the other Contracting State shall be subject to taxation in the first State only if:
(a) the beneficiary shall stay in the other State for one or more periods which do not exceed 183 days in whole in the previous year or in the "year of income" as appropriate; and
(b) the remuneration is paid by the employer or on behalf of an employer who is not domiciled in the other State; and
(c) remuneration does not involve a permanent establishment or a permanent base held by an employer in the other State.
3. Remuneration from employment on board a ship or aircraft operating in international transport by an undertaking of a Contracting State may be taxed in that State, irrespective of the previous provisions of this Article.
TANTIEMS AND REPLACES OF THE COMPANY LEADER
1. Tantiems and similar salaries which are received by a person residing in one Contracting State 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 State.
2. Wages, salaries and other similar remuneration received by a person residing in one Contracting State as the head director of a company having its registered office in the other Contracting State may be taxed in that other State.
Artists and SPORTS
1. Revenue received in public by performers (e.g. theatre, film, radio or television artists and musicians) and athletes from their personal activities as such may be taxed only in the Contracting State in which they are carried out, irrespective of the provisions of Articles 14 and 15. However, such revenue shall not be taxed in that Contracting State if the visit of artists or athletes in that State is, directly or indirectly, fully or substantially supported by the public resources of the other Contracting State.
2. For the purposes of this Article, the term "public funds" shall refer to the resources of the Contracting State, its lower administrative departments, local authorities and other public authorities.
REMUNERATION AND PENSION IN PUBLIC SERVICES
1. (a) Rewards other than pensions paid by a Contracting State, its lower administrative department or local authority to a natural person for services rendered to that State, administrative department or local authority shall be subject to taxation only in that State.
(b) However, such remuneration shall be subject to taxation only in the second Contracting State, where the services were carried out in that other State, the beneficiary shall reside in that State, and
(1) is a State citizen of that State, or
(2) he did not reside in that State solely for the purpose of such services.
2. (a) Any pension paid by a Contracting State, by its lower administrative department or by a local authority or from funds established by them to a natural person for services rendered to that State, administrative department or local office shall be subject to taxation only in that State.
(b) However, such pensions are subject to taxation only in the second Contracting State if the beneficiary is resident in that other State and is a national citizen of that State.
3. The provisions of Articles 15, 16 and 17 shall apply to the remuneration and pensions of services shown in conjunction with an industrial or commercial activity carried out by the Contracting State, its lower administrative department or local authority.
PRIVATE PENSION AND RENTY
(1) Pensions other than those referred to in Article 18 and pensions received by a person resident in one Contracting State from sources in the other Contracting State may be taxed only in the first Contracting State.
2. The term "pension" refers to regular salaries shown in connection with former employment or to compensation for damage to health suffered in the course of employment.
3. The term "rent" refers to a fixed amount of money that is paid regularly during life or for a specified or identifiable period of time on the basis of an obligation to provide such salaries at reasonable and full consideration in money or money valued.
STUDENTS AND TEACHES
1. A natural person resident in one Contracting State and temporarily resident in the other Contracting State only
(a) as a student at a recognised university, college or school in this second contracting state; or
(b) as an apprentice; or
(c) as beneficiary of aid, nutritional or scholarship contributions from state, religious, charitable, scientific, literary or educational organisations,
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Regulation Information
| Citation | Decree of the Minister for Foreign Affairs No. 77 / 1987 Coll., on the Treaty between the Government of the Czechoslovak Socialist Republic and the Government of India on the avoidance of double taxation and the prevention of tax evasion in the field of income taxes |
|---|---|
| Regulation Type | - |
| Author | - |
| Collection | Code of Laws |
| Date of Promulgation | 29.09.1987 |
|---|---|
| Effective from | 13.03.1987 |
| Effective until | - |
| Status | Valid |
The regulation text is for informational purposes only.
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