Treaty On Avoidance Of Double Taxation With Singapore

Original Language Title: Smlouva o zamezení dvojího zdanění se Singapurem

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Read the untranslated law here: https://portal.gov.cz/app/zakony/download?idBiblio=46851&nr=224~2F1998~20Sb.&ft=txt

224/1998 Coll.



The COMMUNICATION FROM the



Ministry of Foreign Affairs



Change: 64/2014 Coll.



Ministry of Foreign Affairs says that on 21 February 2006. November 1997,

in Singapore, an agreement between the Government of the United Kingdom and the Government of

The Republic of Singapore for the avoidance of double taxation and prevention of fiscal

evasion with respect to taxes on income.



With the Treaty, its assent, Parliament of the Czech Republic and the President of the

the Republic has ratified it.



Treaty has entered into force, pursuant to article 27, paragraph 1. 2 day

August 21, 1998.



English translation of the Treaty shall be designated at the same time. In the English version

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

Ministry of Foreign Affairs and Ministry of finance.



CONTRACT



between the Government of the United Kingdom and the Government of the Republic of Singapore for the avoidance of

of double taxation and prevention of fiscal evasion with respect to taxes on income



The Government of the United Kingdom and the Government of the Republic of Singapore, desiring to conclude a

agreement on avoidance of double taxation and the prevention of fiscal evasion with respect

taxes on income, have agreed as follows:



Article 1



The person to which the contract relates



This agreement shall apply to persons who are residents of one or

both of the Contracting States.



Article 2



The tax, to which the contract relates



1. this Agreement shall apply to taxes on income imposed on behalf of each of the

of the Contracting States, or of his lower subdivisions or local authorities,

whatever way to select any.



2. the following shall be regarded as taxes on income all taxes levied on the total

income or on elements of income, including taxes on gains from the alienation of movable

or real estate.



3. Current taxes to which this agreement applies are:



and) in the Czech Republic:



(i) the tax on income of individuals;



(ii) the tax on income of legal persons;

(hereinafter referred to as "Czech tax");



b) in Singapore:



(i) income tax;

(hereinafter called "the Singapore tax").



4. the agreement shall also apply to any tax of the same or

the principle of a similar kind, that will be stored after signature of the contract in addition to the

or instead of the current taxes. The competent authorities of the Contracting States shall mutually

communicate any material changes that will be made in their

the relevant tax laws.



Article 3



General definitions



1. for the purposes of this agreement, unless the context requires a different interpretation:



and) the term "Czech Republic" means the territory in which they are, according to the

Czech legislation and in accordance with international law, exercised

the sovereign rights of the United States;



(b)), the term "Singapore" refers to the Republic of Singapore and, when it is used

in a geographical meaning, include its mainland territory, inland waters

and territorial waters, as well as any seaside area located outside the

the waters, which is or may be in the future, in accordance with the

international law, under its national legislation as

the area where Singapore may exercise sovereign rights or jurisdiction,

as far as the sea, the seabed, the subsoil and natural resources;



(c)) the terms "a Contracting State" and "the other Contracting State" mean, as

context, the Czech Republic or Singapore;



(d)) the term "person" includes an individual, a company and any other

an Association of persons;



(e)) the term "company" refers to any legal entity or

any bearer of Rights considered for taxation purposes legal

person;



(f)) the terms "enterprise of a Contracting State" and "enterprise of the other Contracting

State "means, according to the context, the enterprise carried on by a resident

of a Contracting State and an enterprise carried on by a resident of the other

Contracting State;



(g)) the term "national" means:



(i) any natural person who is a citizen of a Contracting

State;



(ii) any legal person, partnership or association established

According to the law in force in a Contracting State;



h) the term "international traffic" means any transport by boat or

a plane operated by an undertaking which has its place of effective management

in a Contracting State, except when the ship or aircraft

operated solely between places in the other Contracting State;



I) the term "competent authority" means:



(i) in the case of the Czech Republic the Minister of finance or his authorized

representative;



(ii) in the case of Singapore, the Minister of finance or his authorized

representative.



2. As regards the implementation of the Treaty at any time from any of the

of the Contracting States, each expression that is not defined in it, if

the link does not require a different interpretation, of such importance that it has in

This time according to the laws of that State for the purposes of the taxes to the

which the contract applies, any meaning under the used

the tax laws of this State will prevail over the meaning of the expression

under other laws of that State.



3. If the administrator of the trust shall be subject to taxation in one Contracting State

When it comes to dividends, interest or royalties arising

the trust from sources on the territory of the other Contracting State, it is considered that, for the

the purposes of articles 10, 11 and 12 of that administrator is the beneficial owner of

dividends, interest or royalties.



Article 4



A resident of the



1. the term "resident of a Contracting State" means for the purposes of this

of the Treaty, any person who is under the law of that State

subject to taxation in that State by reason of his residence, the Standing

residence, place of management or any other similar criteria, and

It also includes that State and any lower administrative unit, a local authority

or statutory authority of that State.



2. If the individual is under the provisions of paragraph 1, a resident of the

both of the Contracting States, the position specified in the following way:



and) it is assumed that this person is resident only of the State in

which he has a permanent home; If he has a permanent home in both States, assumes

that is a resident only of the State with which it has strong personal and

economic relations (Centre of vital interests);



(b)) if it cannot be determined which state the person Center

their vital interests or if it does not have a permanent home in any State

It is believed to be a resident only of the State in which it is usually

resides;



(c)) If this person usually resides in both States, or in any

of them, it is assumed to be a resident only of the State of which he is

is a national;



d) if the person is not a national of any State, shall adjust the

the competent authorities of the Contracting States the question by mutual agreement.



3. If a person other than an individual is subject to the provisions of paragraph 1,

a resident of both Contracting States, it is assumed to be a resident only

of the State in which the place of effective management.



Article 5



Permanent establishment



1. the term "permanent establishment" means for the purposes of this agreement, the Permanent

place to do business, through which is wholly or partly

carried on the business.



2. the term "permanent establishment" includes especially:



and instead of keeping) local;



(b)) race;



(c));



(d) a factory;)



e) a workshop; and



f) mine, the site of diesel or gas, a quarry or any other place where

the benefits of natural resources.



3. the term "permanent establishment" also includes:



a building site or construction), Assembly or installation project or supervision with

associated, but only if such construction, project or supervision takes

For more than 12 months;



(b)) the provision of services, including consultancy or managerial services,

the enterprise of a Contracting State through employees or

other workers hired by the enterprise for such purpose, but only if

activities such as to insist on the territory of the other Contracting State after

one or more periods exceeding in the aggregate six months within any

the 12-month period.



4. Notwithstanding the preceding provisions of this article, assume that

the term "permanent establishment" shall not include:



and) device that is used only for the purpose of storage, display

or delivery of the goods belonging to the enterprise;



(b)) the supply of goods belonging to the enterprise solely for the purpose

storage, display or delivery;



(c)) the supply of goods belonging to the enterprise solely for the purpose

the processing of another undertaking;



d) permanent place to do business, solely for the purpose of purchasing

goods, or collecting information for the enterprise;



e) permanent place for business, solely for the purpose of

carrying out any other activity that has for undertaking the preparatory or

auxiliary character;



f) permanent place for business, solely to carry out the

any combination of activities mentioned in subparagraphs (a) to (e))), if

the overall activity of the fixed place of business resulting from this

the connection is of a preparatory or auxiliary character.



5. Notwithstanding the provisions of paragraphs 1 and 2, a person-other than

an independent representative, to whom paragraph 6 applies-is acting in a

a Contracting State on behalf of the enterprise and has, and usually uses the permission that

It allows you to enter into contracts on behalf of the company, it is considered that this

the enterprise has a permanent establishment in that State in relation to all activities,

This person performs for the enterprise if the activities of such person are not


limited to the activities listed in paragraph 4 which, if they were

exercised through a fixed place of business, would not based

from this fixed place of business a permanent establishment under for

the provisions of this paragraph.



6. Not considered that the enterprise has a permanent establishment in a Contracting State

just because in this State, carries on business through a

a broker, General Commission agent or any other independent

the representative, if such persons are acting within their proper operation.



7. the fact that a company which is a resident of a Contracting

State controls or is controlled by a company which is a resident of the other

Contracting State or that in that other State carries on business

(whether through a permanent establishment or otherwise), will not make itself from

either this company a permanent establishment of the other company.



Article 6



Income from immovable property



1. Income derived by a resident of a Contracting State from immovable

property (including income from agriculture or forestry) situated in the

the other Contracting State, may be taxed in that other State.



2. the term "immovable property" is of such importance that it under the

the legislation of the Contracting State in which such property is located.

The term includes in any case the accessories of immovable property, live

and dead inventory used in agriculture and forestry, rights to which

the provisions of civil law relating to property, the right to

the enjoyment of immovable property and rights to variable or fixed payments for the

unfair advantage or consent to the mining of mineral deposits, sources and other

natural resources; ships and aircraft shall not be regarded as immovable property.



3. The provisions of paragraph 1 shall apply to income derived from the direct use,

hire or any other manner of use of immovable property.



4. The provisions of paragraphs 1 and 3 shall also apply to the income from immovable property

the assets of the company and to income from immovable property used for

the exercise of an independent profession.



Article 7



The profits of enterprises



1. The profits of an enterprise of a Contracting State shall be taxable only in that

State if the undertaking does not pursue its activities in the other Contracting State

through a permanent establishment that is located there. If

the enterprise carries on business in this way, the profits of the enterprise may be

taxed in the other State, but only to the extent that they can be

attributable to that permanent establishment.



2. If an enterprise of a Contracting State, carries on business in the

the other Contracting State through a permanent establishment that is there

placed, attach, subject to the provisions of paragraph 3 in any

Contracting State of such permanent establishment profits which could

so if it were a separate enterprise carried out the same or

similar activities under the same or similar conditions and was completely

independent contact with the enterprise of which it is a permanent establishment.



3. when calculating the profits of a permanent establishment shall be allowed to deduct the costs of

spent on the objectives of the permanent establishment, including Executive and

General administrative expenses, whether incurred in this way in the State

which the permanent establishment is situated or elsewhere.



4. If a Contracting State determine the gains that

to be attributed to a permanent establishment on the basis of allocation of the total

the profits of the enterprise to its various parts, nothing in paragraph 2 shall not preclude the

This Contracting State the profits to be taxed by the usual

the Division; the method of distribution must, however, be such that the result of the

in accordance with the principles laid down in this article.



5. no permanent establishment of nepřičtou gains based on the fact that

only goods for the company.



6. The profits to be attributed to a permanent establishment for purposes of

the preceding paragraphs shall each year, in the same way, if the

There are insufficient grounds for a different procedure.



7. where profits include the part of the income which are dealt with separately

in the other articles of this agreement, the provisions of those articles shall not affect the

the provisions of this article.



Article 8



Water and air transport



1. Profits from the operation of ships or aircraft in international traffic

shall be taxable only in the Contracting State in which the place of

effective management of the enterprise.



2. If the place of effective management of the enterprise is aboard a ship, it is considered

situated in the Contracting State in which the home port

the ship, or, if there is no such home harbour, in the Contracting State of which the

operator of the ship is a resident.



3. for the purposes of this article, and regardless of the provisions of article 12, gains

from the operation of ships or aircraft in international traffic shall also include:



and rental) gains from ships or aircraft without the crew and



(b)) gains from use, maintenance or rental of containers (including trailers and

related equipment for the transport of containers) used for the

the carriage of goods,



where such rental or such use, maintenance or rental,

Depending on what matters, occasionally in relation to the operation of ships

or aircraft in international traffic.



4. interest arising in a Contracting State and received from the funds

generated in that Contracting State as an integral part of the exercise

activities involving the operation of ships or aircraft in international

transport shall be regarded as profits from the operation of such ships or aircraft, in the

international transport and the provisions of article 11 shall not apply in relation to the

such interest.



5. The provisions of paragraph 1 shall also apply to profits from the participation in a pool,

the joint operation or an international operating organization.



Article 9



Associated enterprises



1. If the



and the company) of a Contracting State participates directly or indirectly in the

the management, control or capital of an enterprise of the other Contracting State, or



(b)) the same persons participate directly or indirectly in the management, control or

capital of an enterprise of a Contracting State and enterprise of the other Contracting

State



and if in these cases are both enterprises in their commercial or

bound by the terms of the financial relations which have negotiated or they were

stored and which differ from those which would have been agreed upon between the

independent enterprises, can any profits which would, but for those

conditions have been accrued to one of the enterprises, but due to these

conditions were not achieved, be included in the profits of this business and

subsequently taxed.



2. where a Contracting State includes in the profits of the enterprise of that State-and

Subsequently, the tax-gains that enterprise of the other Contracting State has been

taxed in that other State and the other Contracting State agrees that the profits

these steps included are profits which would have accrued to the enterprise of the former

of that State, if the conditions agreed between the two companies were

What would have been agreed between independent undertakings, adjusted this

the second State reasonably amount of tax imposed on these profits there. When

the determination of this adjustment, taking into account the other provisions of this Treaty

and, if necessary, the competent authorities of the Contracting States to this end

advise each other.



3. The provisions of paragraph 2 shall not apply in the case of fraud, gross

negligence or wilful neglect.



Article 10



Dividends



1. dividends paid by a company which is a resident of a

of a Contracting State to a resident of the other Contracting State may be taxed in the

that other State.



2. However, such dividends may also be taxed in the Contracting State,

of which the company paying the dividends is a resident and according to the laws

laws of that State, but if the beneficial owner of the dividends is

a resident of the other Contracting State, the tax so charged shall not exceed 5

per cent of the gross amount of the dividends. The competent authorities of the Contracting States shall

by mutual agreement the mode of application of this limitation.



This paragraph shall not affect the taxation of the profits of the company, all of which are

dividends are paid.



3. the term "dividends" as used in this article means income from shares

or other rights, with the exception of receivables, with a share of the profits, as well as

other revenues, which are subjected to the same tax regime as income

of the shares under the laws of the State of which the company

rozdílí profit, a resident.



4.



a) Notwithstanding the provisions of paragraph 2, dividends paid by a company

that is a resident of Singapore to a resident of the United States are not subject to

tax on dividends in addition to the tax on profits or income of the company, because the

under the laws of Singapore, there is no income tax,

that would impose on dividends in addition to the tax on profits or income

the company.



(b)) when you subsequently after the signing of the Treaty will choose Singapore tax

dividends in addition to the taxes levied on the profits or income of the company that

is a resident of Singapore, such a tax could be imposed, but a tax on

dividends received by a resident of the United States, which is the actual

the owner of such dividends, will be stored in accordance with the provisions of

of paragraph 2.



5. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of

of the dividends, being a resident of a Contracting State, carries on business in the

the other Contracting State of which he is a resident company paying

dividends, industrial or commercial activity through a fixed


the establishment, which is located there, or performs in that other State

independent profession from a permanent base located there and if the participation, for the

which the dividends are paid is effectively connected to such permanent establishment

or a permanent base. In such a case, the provisions of article 7

or article 14, depending on what matters.



6. Where a company which is a resident of a Contracting State,

achieves profits or income from the other Contracting State, that

the second State to tax dividends paid by the company, unless such

dividends are paid to a resident of that other State or to participate,

for which the dividends are paid is effectively binds to a permanent establishment

or a permanent base, which is located in that other State, nor

subject to the company's retained profits tax on retained earnings

the company, even if the dividends paid or the undistributed profits

consists wholly or partly of profits or income with a source in the

that other State.



Article 11



Interest



1. interest arising in a Contracting State and paid to a resident of the

of the other Contracting State shall be taxable only in that other State,

If the resident is the beneficial owner of the interest.



2. The term "interest" as used in this article means income from debt-claims

of any kind, whether or not a lien on

real estate or whether or not carrying a right to participate in the debtor's profits,

and in particular, income from government securities and income from bonds or

debentures, including premiums and prizes attaching to such a valuable

securities, bonds or debentures. Penalty charges for late payment shall

not regarded as interest for the purpose of this article. Expression of interest does not include the

No part of the income that is treated as a dividend under the provisions of

Article 10, paragraph 3.



3. The provisions of paragraph 1 shall not apply if the beneficial owner of

of the interest, being a resident of a Contracting State, carries on business in the other

the Contracting State in which they have interest, industrial or commercial source

activity through a permanent establishment situated therein, or

performs in that other State independent of the profession of a permanent base there

placed and if the claim from which the interest is paid,

actually attaches to such permanent establishment or fixed base. In such a

If the provisions of article 7 or article 14, depending on

What matters.



4. It is assumed that interest to arise in a Contracting State when the

the payer is a resident of that State. However, if the payer of interest, whether

or is not a resident of a Contracting State, has in a Contracting State

a permanent establishment or a fixed base in connection with which there has been a

debt, from which interest paid, and such interest shall be charged to such

permanent establishment or fixed base, it is assumed that such interest

to arise in the State in which the permanent establishment or a permanent

the base is located.



5. If the amount of interest that are applicable to the claim from which they are

paid, exceeds, due to the special relationship between the payer and the

the beneficial owner or between both of them and some other person,

the amount you would have been had given the Bill-to customer is the beneficial owner, if

There was no such relationship, the provisions of this article shall apply only to that

latter amount. The amount of the payments, which will be in excess

this case taxed in accordance with the laws of each Contracting

State with regard to the other provisions of this Treaty.



Article 12



License fees



1. Royalties arising in a Contracting State and paid to the

a resident of the other Contracting State may be taxed in that other

State.



2. However, Such royalties may be, except in the case of a species of payments,

that is listed in subparagraph (a)), paragraph 3, also taxed in the Contracting

State in which they arise, and according to the laws of that State,

But if the beneficial owner of the royalties is a resident of

of the other Contracting State, the tax so charged shall not exceed:



a) 5 percent of the gross amount of the royalties, in the case of

payments, that is listed in subparagraph (b)), paragraph 3;



b) 10 per cent of the gross amount of the royalties, in the case of

payments, that is listed in subparagraph (c)), paragraph 3.



The competent authorities of the Contracting States shall by mutual agreement settle the mode

the application of these restrictions.



3. the term "royalties" means payments of any kind received

as a substitute for the use of, or the right to use:



and) any copyright for literary, artistic or

scientific, with the exception of a computer program, and including

Cinematograph films, and films or tapes for television or

radio broadcasting;



(b)) of any industrial, commercial or scientific equipment;



(c)), any patent, trade mark, design or model, plan,

the secret formula or process, and a computer program, or for the information,

that applies to experience acquired in the field of industrial, commercial

or scientific.



4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of

of the royalties, being a resident of a Contracting State,

carries on in the other Contracting State in which the royalties

source, industrial or commercial activity through a fixed

the establishment, which is located there, or performs in that other State

independent profession from a permanent base located there, and if the right or

assets that give the emergence of royalty actually bind to

such permanent establishment or fixed base. In that case, shall apply

the provisions of article 7 or article 14, depending on what matters.



5. It is assumed that the licence fees to arise in a Contracting State,

If the payer is a resident of that State. However, if the payer

royalties, whether he is or is not a resident of a Contracting

State, has in a Contracting State a permanent establishment or a fixed base in

connection with which the obligation to pay the royalties was created, and these

royalties are borne by such permanent establishment or a permanent

the base, it is assumed that these licence fees should arise in the

State in which the permanent establishment or fixed base is situated.



6. If the amount of the license fees that are related to the use,

law or information for which they are paid, exceeds, in consequence of the

the special relationship between the payer and the beneficial owner or between both of

them and some other person, the amount which would have been had given the Bill-to customer is

the beneficial owner, if it wasn't for such relationships, the

the provisions of this article to the latter amount. The amount of the

payments that it exceeds, in this case, will be taxed in accordance with the

the laws of each Contracting State, taking into account the other

the provisions of this agreement.



Article 13



Gains from the alienation of property



1. Gains derived by a resident of a Contracting State from the alienation of

immovable property referred to in article 6, which is located on the second

a Contracting State may be taxed in that other State.



2. Gains from the alienation of movable property forming part of the business property of a

a permanent establishment which an enterprise of a Contracting State in the other

Contracting State or of movable property belonging to the permanent base

that is a resident of a Contracting State in the other Contracting State for the

the purpose of the exercise of an independent profession, including gains from the alienation of such

a permanent establishment (alone or together with the whole enterprise) or of such a

fixed base, may be taxed in that other State.



3. Gains from the alienation of ships or aircraft operated in international

transport or movable property, which is used to operate these ships

or aircraft, shall be taxable only in the Contracting State in which the

the place of effective management of the undertaking.



4. Gains from the alienation of any property, other than that referred to in

paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which he is

alienator is a resident.



Article 14



An independent profession



1. Income derived by a resident of a Contracting State from the free

profession or other activities of an independent character, shall be subject to

taxable only in that State except in the following cases, when such

income may also be taxed in the other Contracting State:



and if you want this) resident regularly available in the other Contracting

State a permanent base for the purpose of carrying out its activities; in such a

the case of just such a part of the income which is attributable to that fixed base,

may be taxed in that other State; or



b) if his stay in the other State for a period or multiple periods

exceeds 183 days in the aggregate in any twelve month period; in

this case just a portion of the revenue, which is the amount received from its

activities carried on in that other State, may be taxed in this

the second State.



2. The counting period referred to in paragraph 1 (b). (b)) are included

on the following days:



and all the days of physical presence), including arrivals and departures, and



b) days spent outside the State activities, such as business trips directly


associated with the exercise of the activities of the recipient in that State, Saturday and Sunday,

national holidays and leave, after which it was to operate on the territory of that

State.



3. the term "liberal profession" includes especially independent activity

scientific, literary, artistic, educational or teaching, as well as

the independent activities of physicians, lawyers, engineers, architects, dentists and

accounting experts.



Article 15



Employment



1. a salaries, wages and other similar remuneration derived by a resident of a

of a Contracting State by reason of employment, shall, subject to the provisions of

articles 16, 18 and 19 of the taxable only in that State unless the employment is not

exercised in the other Contracting State. If there is a job to be exercised,

the rewards from it may be taxed in that other State.



2. remuneration derived by a resident of a Contracting State by reason of the

employment exercised in the other Contracting State, shall be subject to whatever

the provisions of paragraph 1, taxable only in the first-mentioned State if

all of the following conditions are met:



and the recipient) is employed in other State for a period or multiple periods

not exceeding in the aggregate 183 days in any twelve month period, and



(b)) the rewards are paid by the employer or by the employer, that

is not a resident of the other State, and



(c) the remuneration is not borne by) of a permanent establishment or a fixed base, which has

employer in the other State.



3. The counting period referred to in paragraph 2 (a). and) include

on the following days:



and all the days of physical presence), including arrivals and departures, and



b) days spent outside the State activities, such as business trips directly

associated with employment of the recipient in that State, Saturday and Sunday, the national

holidays and leave, after which it was to operate in the territory of that State

continued.



4. Notwithstanding the preceding provisions of this article may be rewards

received because of employment exercised aboard a ship or aircraft

operated in international traffic are taxed in the Contracting State in which the

the place of effective management of the enterprise.



Article 16



Royalties



Directors ' fees and other similar payments derived by a resident of a Contracting

the State as a member of the management board or any other similar authority

a company which is a resident of the other Contracting State, may be

taxed in that other State.



Article 17



Artists and athletes



1. Income derived by a resident of a Contracting State as to the

public entertainer, such as a theatre, film, radio or

television artist, or a musician, or as an athlete of such personally

activities in the other Contracting State, may be, regardless of the

the provisions of articles 14 and 15 of the taxed in that other State.



2. If the income from the activities carried out by the artist in person or

athlete or in connection with them are artists or athletes

self, but to another person, may be those revenues regardless of the

the provisions of articles 7, 14 and 15, be taxed in the Contracting State in which they are

the activities of the artist or athlete are exercised.



Article 18



Board



Pensions and other similar salaries paid to a resident of a Contracting State

due to past employment shall, subject to the provisions of article

19 para. 2 taxable only in that State.



Article 19



Public function



1.



a) salaries, wages and other similar remuneration, other than a pension paid by one

a Contracting State or a political subdivision or a local authority or

the statutory authority of that State, of a natural person for services rendered

to that State or subdivision or authority or authority shall be taxable only in the

This state.



(b)), Such salaries, wages and other similar remuneration shall be taxable only, however,

in the other Contracting State if the services are rendered in that

State, and the natural person who is a resident of this State:



(i) is a national of that State; or



(ii) did not become a resident of that State only because of the proof of these

services.



2.



and pension paid by one) of any Contracting State or lower administrative

Department or local authority or a statutory body of that State, or

paid from the funds, which have established, the physical person for services rendered

to that State or subdivision or authority or authority shall be taxable only in the

This state.



(b) However, Such pension) shall be taxable only in the other Contracting State,

If the individual is a resident of, and a national of that

State.



3. the provisions of articles 15, 16 and 18 shall apply to salaries, wages and other

similar remuneration and pensions for services rendered in connection with the industrial

or commercial activity carried out by any Contracting State or lower

Administrative Department or local authority or a statutory body of the

State.



Article 20



Students



The payments it receives for the purpose of reimbursement of the costs of their nutrition, education

or the training of a student or an apprentice who is, or immediately before the

arriving in one Contracting State he was a resident of the other Contracting

State and who is present in the first-mentioned State solely for the purpose of its

education or training, are not subject to tax in that State in

provided that such payments arise from sources outside that State.



Article 21



Other revenue



Part of the revenues, which are not dealt with in the foregoing articles, and having

the source in a Contracting State may be taxed in that State.



Article 22



Elimination of double taxation



1. subject to the provisions of the legislation of Singapore relating to the

Elimination of double taxation, will be in the case of a resident of Singapore, double

taxation out of the question as follows:



If a resident of Singapore derives income from the United States, which may

be in accordance with the provisions of this agreement, taxed in the Czech Republic,

Singapore will allow as a credit to the Singapore income tax due

This resident of the Czech tax paid, whether directly or by deduction. If

This income is a dividend paid by a company which is a resident of

The United States to a resident of Singapore, which is a company that owns

directly or indirectly not less than 10 percent of the share capital for the first time

the mentioned company, takes into account when credit Czech tax paid

This company from a part of the profits out of which the dividend is paid.



2. subject to the provisions of the legislation of the United Kingdom of

the Elimination of double taxation, will be in the case of a resident of the United States

double taxation is excluded as follows:



and Czech Republic) may, when depositing taxes its residents included in the

the tax base from which to impose such a tax, part of the revenue,

that may be, in accordance with the provisions of this Treaty also taxed in the

Singapore, however, allows to reduce the amount of tax calculated from such

an amount equal to the tax paid in Singapore. The amount of the

the tax to be reduced, however, shall not exceed that part of the Czech taxes calculated before

the reduction, which rather falls on revenue that may be in

accordance with the provisions of this Treaty are taxed in Singapore.



(b)) If, in accordance with any provision of the contract, income

received by a resident of the United States shall be exempt from taxation in the United

Republic, the Czech Republic may nevertheless, in calculating the amount of tax

the remaining income of such resident, take into account the exempted income.



Article 23



Prohibition of discrimination



1. nationals of a Contracting State shall not be subjected in the

the other Contracting State to any taxation or any requirement connected therewith

United, which is other or more burdensome than the taxation and connected with it

the obligations to which they are or may be subjected by nationals

This second State, in particular with respect to residence, in

the same situation. This provision shall, notwithstanding the provisions of article 1 of

also apply to persons who are not residents of one or both of the

of the Contracting States.



2. the taxation on a permanent establishment which an enterprise of a Contracting State in the

the other Contracting State, that other State will not be less favourable than

taxation of enterprises of that other State carrying out the same activities.



3. If you do not apply the provisions of article 9, paragraph 1. 1, article 11

paragraph. 5 or to article 12 para. 6, interest, royalties and other

expenses paid by the enterprise of a Contracting State to a resident of the other

Contracting State deductible for purposes of determining taxable profits

of the undertaking under the same conditions as if they had been paid to the

a resident of the first-mentioned State.



4. nothing in this article shall be construed as a commitment of a Contracting

State admitted:



and) to residents of the other Contracting State any personal credits, discounts and

the tax reduction, which it grants to its own residents; or



(b)) to nationals of the other Contracting State such personal relief,

discounts and reductions, which grants to its own nationals

Members who are not residents of the first-mentioned State or other

persons, as may be prescribed in the tax code first mentioned

State.



5. enterprises of a Contracting State, the capital of which is wholly or partly,

directly or indirectly owned or controlled by one or more


residents of the other Contracting State, shall not be subjected in the first-mentioned

State to any taxation or any requirement connected therewith, which

is other or more burdensome than the taxation and connected requirements to which

are or may be subjected to other similar businesses of former

State.



6. If the Contracting States shall, in accordance with its national policy and

the criteria of tax breaks to their nationals to support the

economic or social development, it will not be construed as a

discrimination under this article.



Article 24



Resolving cases by agreement



1. where a person considers that the actions of one or both of the Contracting

States lead or lead it to taxation not in accordance with the

the provisions of this agreement, he may, irrespective of the remedies,

that provide the national law of those States, present

his case to the competent authority of the Contracting State of which he is a resident of,

or if her case falls under article 23 paragraph 1. 1, the Office of the Contracting

the State of which he is a national. The case must be presented within three

years from the first notification of the action of the head of taxation which is not in the

accordance with the provisions of the Treaty.



2. If the competent authority of the objection to be justified and

If it is not itself able to find a satisfactory solution, it will try to

case solved by mutual agreement with the competent authority of the other Contracting

the State so as to avoid taxation which is not in accordance with the Treaty.

Any agreement reached will be made without regard to any

the time limits in the domestic law of the Contracting States.



3. the competent authorities of the Contracting States shall endeavour to resolve by mutual

the agreement any difficulties or doubts that might arise in

the interpretation or application of this agreement. They may also consult together for the

the purpose of the Elimination of double taxation in cases not covered by the contract.



4. the competent authorities of the Contracting States may come in direct contact with a view to

reaching an agreement in the sense of the preceding paragraphs. If oral

Exchange of views appears to be effective for the achievement of the agreement, can such exchange

take place through a Commission consisting of representatives of the competent authorities

of the Contracting States.



Article 25



The exchange of information



1. the competent authorities of the Contracting States shall exchange such information,

for which it can be assumed that they are relevant to the implementation of the

the provisions of this contract or in relation to the implementation or enforcement of the

the national legislation of the Contracting States, which apply to

taxes of every kind and name stored on behalf of the Contracting States or

their lower subdivisions or local authorities, if the taxation

that edit is not in breach of contract. Exchange of information is not

restricted by articles 1 and 2.



2. any information received by a Contracting State under paragraph 1 shall be

kept a secret in the same manner as information obtained under the

national law of that State and shall be made available only to

to persons or authorities (including courts and administrative authorities), which deal with

charge of the assessment or collection of taxes, which are listed in paragraph 1,

enforcement or criminal prosecution in the case of such taxes, deciding about

appeals in respect of those taxes or above

said. Such persons or authorities shall use the information only to those

purposes. They may disclose the information in public court proceedings

or in judicial decisions.



3. The provisions of paragraphs 1 and 2 shall not be in any way interpreted as

store the Contracting State the obligation:



and perform administrative measures) that would infringe on the laws and

the administrative practice of that or of the other Contracting State;



(b)) to provide information that cannot be obtained on the basis of the legal

regulations or in the normal course of administrative proceedings of this or of the other Contracting

State;



c) to supply information which would disclose any trade,

economic, industrial, commercial or professional secret or of a commercial

procedure, or information, the disclosure of which would be contrary to the public

policy.



4. where, in accordance with this article in one Contracting State

required information, the other Contracting State shall use its measures

aimed at obtaining information, in order to obtain the requested information, even

When this second State does not need such information for its own

tax purposes. The obligation contained in the preceding sentence is subject to restrictions

paragraph 3, but in any case, these limits will not be interpreted as

allow the Contracting Government refuse to provide information only

because it has no domestic interest in such information.



5. The provisions of paragraph 3 shall not be in any way interpreted as

allow the Contracting Government refuse to provide information only

the reason that the information has a Bank, other financial institution,

trustee or person acting on behalf of or as agent,

or because the information is relevant to the ownership shares of the person.



Article 26



Members of diplomatic missions and consular officials



Nothing in this Agreement shall affect the fiscal privileges of members of diplomatic missions

or consular officials attributed to them on the basis of the General

rules of international law or under the provisions of the Special

agreements.



Article 27



Entry into force



1. the Contracting States shall notify each other that the requirements of the national

laws for the entry into force of this agreement have been fulfilled.



2. the contract shall enter into force on the date of the later of the notifications referred to in

paragraph 1 of this article and its provisions will be implemented:



and) in the Czech Republic:



(i) in respect of taxes withheld at source, on income paid

or credited to 1. January or later in the calendar year

following the year in which the Agreement enters into force;



(ii) in respect of other taxes on income, the income for each tax year

beginning with 1. January or later in the calendar year following the

year in which the Agreement enters into force;



b) in Singapore:



as for the tax to be imposed on for each year of assessment beginning on 1. January

or later in the second calendar year following the year in which the

The Treaty enters into force.



Article 28



Notice of termination



This agreement shall remain in force until denounced by one

Contracting State. Each Contracting State may, through the diplomatic channel administration

written notice to terminate the contract for at least six months before the end of

each calendar year following after the period of five years from the date of

the entry into force of the Treaty. In this case, the contract ceases to

carry out:



and) in the Czech Republic:



(i) in respect of taxes withheld at source, on income paid

or credited to 1. January or later in the calendar year

following the year in which the notice of termination has been given;



(ii) in respect of other taxes on income, the income for each tax year

beginning with 1. January or later in the calendar year following the

year in which the notice of termination has been given;



b) in Singapore:



as for the tax to be imposed on for each year of assessment beginning on 1. January

or later in the second calendar year following the year in which the

notice has been given.



In witness whereof, the duly authorised thereto, have signed this agreement.



Done at Singapore on 21. November 1997, in two original copies

in the English language.



For the Government of the United States:



Ivan Pilip in r.



For the Government of the Republic of Singapore:



Richard Hu in r.



PROTOCOL



When signing the contract between the Government of the United Kingdom and the Government of Singapore

States on avoidance of double taxation and the prevention of fiscal evasion with respect

taxes on income, the undersigned have agreed upon the following provisions,

which forms an integral part of the contract.



1. where this Treaty provides for (with or without conditions),

income from sources in the Czech Republic is exempt from taxation, or is in the

The Czech Republic are taxed at a reduced rate, and according to the applicable laws and

law in Singapore is that income is subjected to taxation by reference to

the amount of that income, which is remitted to or received in Singapore

Singapore, and not by reference to the full amount of this income, then

the exemption or reduction of tax which is allowed under this agreement in

The Czech Republic, applies only to that portion of the income that is remitted to the

Singapore or received in Singapore. However, this restriction shall not apply to

income received by the Government of Singapore or any person recognized

the competent authority in Singapore for the purposes of this paragraph. The expression "Government

Singapore "includes its agencies and statutory bodies.



2. In the event that after the signature of this agreement, signed by the Czech Republic with

third State contract stipulating that for dividends paid by

a company which is a resident of a third State, society,

that is a resident of the United States, the reduction provided for in article

22 paragraph 1. 2 (a). and) of the Treaty shall take account of the tax paid by the company of

the profits out of which such dividends are paid, it is automatically

for the purposes of this provision of the Treaty on dividends paid by a company

that is a resident of Singapore, a company that is a resident of the United


States and that directly or indirectly owns no less than 10 percent of

the share capital of the company of Singapore, and as from the date when the contract

between the Czech Republic and this third State shall take effect.



In witness whereof, the duly authorised thereto, have signed this

Protocol.



Done at Singapore on 21. November 1997, in two original copies

in the English language.



For the Government of the United States:



Ivan Pilip in r.



For the Government of the Republic of Singapore:



Richard Hu in r.