Changes To The Treaty On The Avoidance Of Double Taxation With The Netherlands

Original Language Title: Změny Smlouvy o zamezení dvojího zdanění s Nizozemskem

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112/1997.



The COMMUNICATION FROM the



Ministry of Foreign Affairs



Ministry of Foreign Affairs says that the 26 July. in June 1996 he was

Prague signed the additional protocol to the Treaty between the Czechoslovak

Socialist Republic and the Kingdom of the Netherlands for the avoidance of double

taxation and prevent tax leakage in the field of taxes on income and capital and

Protocol. 1) the Treaty between the Czechoslovak Socialist Republic

and the Kingdom of the Netherlands on the avoidance of double taxation and the prevention of

tax leakage in the field of taxes on income and on capital and the Protocol of 4 February.

March 1974 were promulgated under no. 138/1974 Coll.



With the agreement, the Parliament of the Czech Republic and the President of the

Republic has ratified it.



Protocol entered into force pursuant to its article 6 on 11 August. April

1997.



The Czech text of the Protocol shall be published at the same time. In the English version

The Protocol, which is for its interpretation of the applicable, can be consulted on the

Ministry of Foreign Affairs and the Ministry of finance.



PROTOCOL



additional Agreement between the Czechoslovak Socialist Republic and the

Kingdom of the Netherlands on the avoidance of double taxation and prevention of tax

the leak in the field of taxes on income and on capital and the Protocol to it



Czech Republic and the Kingdom of the Netherlands,



Desiring to supplement the Treaty between the Czechoslovak Socialist

Republic and the Kingdom of the Netherlands for the avoidance of double taxation and the

prevent tax leakage in the field of taxes on income and on capital and the Protocol to the

it, signed in Prague 4. March 1974 (hereinafter referred to in this Protocol,

The "Treaty"),



have agreed as follows:



Article 1



Article 5 of the Treaty shall be amended by adding immediately after paragraph (f))

paragraph 2, the following new subparagraph:



"(g) a building site or construction or) Assembly, which last more than twelve

months. "



and the deletion of subparagraph (f)), paragraph 3.



Article 2



Article 6 of the Treaty is amended by the deletion of the second sentence of paragraph 2, the words

"and claims of any kind, secured by a lien on the

the property, with the exception of the bonds ".



Article 3



Article 11 of the Treaty shall be amended by the deletion of paragraph 2 and its substitution

the following text:



"2. The term" interest "as used in this article refers to the revenue from the public

bonds, bonds, or debentures secured and unsecured

a lien on the real estate, if you do not provide the right to share in the

profit and claims of any kind, as well as all other

income assimilated to income from loans, tax legislation of the State in

which have this revenue source. ".



Article 4



Article 14 of the Treaty shall be amended by inserting a new paragraph after paragraph 4

This wording:



"5. The provisions of paragraph 4 shall not affect the rights of either of the Contracting States

choose according to their own laws, tax on profits from the disposal of shares

or exploitation rights to a company whose capital is wholly or

partly divided into shares and which, under the laws of the State of residence

in this State, received a natural person who resides in the second

State and was domiciled in that State, for the first time during the last five

years preceding the alienation of the shares or the exploitation rights. ".



Article 5



Article 25 of the Treaty shall be amended by adding subparagraph 3 of paragraph and

immediately after the words "article 12 paragraph 2" as follows:



"article 14, paragraph 5"



and the addition of subparagraph 2 of paragraph (B) immediately after the words "in articles

10, 12.0 "as follows:



"14".



Article 6



This Protocol, constituting an integral part of the Agreement, shall enter into force

on the 30th day after the date of the later of the notifications by which the Government

in writing, that the requirements have been complied with constitutional rules

the relevant States, and its provisions will apply to tax years

and the period starting on 1 July. January or later in the calendar year

following the year in which the later of the notifications has been received.



On the evidence of subscribers, duly authorised thereto, have signed this

Protocol.



Done in duplicate in Prague on 26. 6. year one thousand devítistého

ninetieth sixth in Czech, Italian and English, with

all three texts being equally authentic. If there is a different interpretation of the

the Czech and Dutch text, the English text will be decisive.



For the Czech Republic:



Ivan Kočárník, in r.



For the Kingdom of the Netherlands:



P. f. c. Koch in r.

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