Agreement For The Avoidance Of Double Taxation With Israel

Original Language Title: Smlouva o zamezení dvojího zdanění s Izraelí

Read the untranslated law here: https://portal.gov.cz/app/zakony/download?idBiblio=42641&nr=21~2F1995~20Sb.&ft=txt

21/1995 Coll.
COMMUNICATION

Ministry of Foreign Affairs


Ministry of Foreign Affairs informs that on 12 December 1993 was in Jerusalem
signed the Treaty between the Czech Republic and the State of Israel
Avoidance of Double Taxation and Prevention of Fiscal Evasion with respect to taxes on income
.

With the Treaty approved by the Parliament of the Czech Republic and President of the Republic ratified
. The instruments of ratification were exchanged in Prague on
23rd December 1994.

Treaty entered into force by virtue of Article 29, paragraph. 2 day
23rd December 1994.

Czech translation of the Treaty shall be open simultaneously. In the English version, which is
for its interpretation applicable, can be consulted at the Ministry
Foreign Affairs and the Ministry of Finance.


AGREEMENT
Between the Czech Republic and Israel for the avoidance of double taxation and
Prevention of Fiscal Evasion of income taxes

Government of the Czech Republic and the Government of Israel

Desiring to conclude a Treaty on Avoidance of Double Taxation and the Prevention
Fiscal Evasion with respect to Taxes on Income

And promote the further development of mutual relations

Agree as follows:
Article 1


Persons to which the Convention applies

This Agreement shall apply to persons who are resident in
one or both of the Contracting States (residents).
Article 2


Taxes to which the Convention applies

First This Convention shall apply to taxes on income imposed on behalf of
a Contracting State or its political subdivisions or local authorities
, irrespective of the manner levied.

Second Taxes on income are considered all taxes imposed on total
income or on elements of income, including taxes on gains from the alienation of movable or
immovable property, taxes on the total amounts of wages or salaries paid by enterprises
well as taxes on capital property.

Third The existing taxes to which the Convention applies are:

A) in the Czech Republic:

(I) the income tax;

(Ii) the tax on corporate income;

(Hereinafter referred to as "Czech tax");

B) in Israel

(I) taxes imposed under the Law on Income Tax (Income Tax Ordinance) and
related laws;

(Ii) the profit tax and payroll tax
financial institutions and insurance companies;

(Hereinafter referred to as "Israeli tax").

Fourth This agreement will also apply to taxes
same or similar kind which are imposed after the signature of this contract
alongside or in place of existing taxes. The competent authorities of the Contracting States shall notify each other
substantial changes which have been made in their respective taxation laws
.
Article 3



General Definitions
First For the purposes of this Agreement, unless the context otherwise requires:

A) the term "Czech Republic" means the territory to which they apply tax laws
Czech Republic;

B) the term "Israel" means the State of Israel in accordance with its laws and if
used in a geographical sense includes, but is not limited to territorial waters
Israel and any area outside the territorial waters, which
accordance with the laws of Israel's territory in which they can be exercised rights of Israel
related to the exploration and exploitation of natural, biological and mineral resources
located in the sea water on the seabed and subsoil of these
water treatment;

C) the terms "a Contracting State" and "the other Contracting State" mean
the Czech Republic and Israel;

D) the term "person" includes an individual, a company and any other body of persons
;

E) the term "company" means any body corporate or any entity,
is treated for tax purposes as a legal entity;

F) the terms "enterprise of a Contracting State" and "enterprise of the other Contracting State
" mean an enterprise carried on by a resident of a Contracting State
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 deriving
under the laws of a Contracting State;

H) the term "international traffic" means any transport
by a ship, aircraft or road vehicle, which is
operated by an enterprise which has its place of effective management in a Contracting State
if such a right is not
solely between places in the other Contracting State;


I) the term "competent authority" means:

(I) in the case of the Czech Republic - Minister of Finance or his authorized representative
;

(Ii) in the case of Israel - the Minister of Finance or his authorized representative
.

Second Any term not otherwise defined, shall have the application of this treaty Contracting State
meaning which it has under the law of that State
concerning the taxes covered by this Agreement, unless the context otherwise requires
interpretation.
Article 4

The tax residence


First For the purposes of this Convention, the term "resident of a Contracting State"
means any person who, under the law of that State
undergone in the State of taxation by reason of his domicile, residence, place
management, place of incorporation or any other similar criteria.
This term does not include any person who is liable to tax in that Contracting State
only of income from sources in that State or
assets located in that State.

Second If the individual is under the provisions of paragraph 1
resident of both Contracting States, then his status shall be determined as follows
way:

A) It is assumed that this person is a resident of the State in which he has a permanent home
; if he has a permanent home in both States, it is assumed that
a resident of the state, which has closer personal and economic relations
(center of vital interests);

B) if it can not be determined, the State in which he has his center of vital interests
or if he has a permanent home in any state
assumed that a resident of the State in which they are usually | || resides;

C) if he has an habitual abode in both States or in neither of them
, it is assumed that a resident of the State whose nationality
national;

D) if he is a national of both States or of neither
of them, the competent authorities of the Contracting States
question by mutual agreement.

Third If a person other than an individual under the provisions of paragraph 1
resident of both Contracting States, that is resident in
the State in which the place of effective management. If
State in which the place of effective management can not be determined,
the competent authorities of the Contracting States the question by mutual agreement.
Article 5

Permanent establishment


First For the purposes of this Convention, the term "permanent establishment" means a fixed place of business
in which the enterprise is wholly or partly
its activities.

Second The term "permanent establishment" includes especially:

A) a place of management;

B) plant;

C) an office;

D) a factory;

E) a workshop; and

F) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources
.

Third The term "permanent establishment" also includes:

) A building site or construction, installation or assembly project, but only lasts
if such site or project more than 12 months;

B) the provision of services, including consultancy and managerial services, provided
enterprise through employees or other
workers employed by the enterprise for such purposes, but only if
such activities continue (for the same or related || | project) within the country for a period or periods exceeding in the aggregate
more than six months in any twelve month period.

Fourth Notwithstanding the preceding provisions of this Article,
the term "permanent establishment" shall not include:

A) equipment which is used only for storage, display or delivery of goods
belonging to the enterprise;

B) the supply of goods or merchandise belonging to the enterprise solely for the purpose
storage, display or delivery;

C) the supply of goods or merchandise belonging to the enterprise solely for the purpose
processing by another enterprise;

D) the maintenance of a fixed place of business solely for the purpose
purchasing goods or collecting information for the enterprise;

E) the maintenance of a fixed place of business maintained for the enterprise solely for the purpose
advertising, providing information, scientific research or similar
activities which have for preparatory or auxiliary character;

F) the maintenance of a fixed place of business solely for
any combination of activities mentioned in subparagraphs a) - e) if

Overall activity of the fixed place of business resulting from this combination is
preparatory or auxiliary character.

Fifth Notwithstanding the provisions of paragraphs 1 and 2, a person - other than
independent agent to whom paragraph 6 applies - is acting in
Contracting State on behalf of an enterprise and has, and habitually too
that authority to conclude contracts on behalf of the company, it is understood that
this enterprise has a permanent establishment in that State in respect of any
activities which that person undertakes for the enterprise, unless the activities of such person are
limited to those mentioned in paragraph 4 which, if exercised through
permanent facility, would not
existence of a permanent establishment under the provisions of this paragraph.

6th They are not considered, the enterprise has a permanent establishment in a Contracting State
just because in this state carries out its activities through
broker, general commission agent or other independent agent
if such persons are acting in the ordinary course of their activity.

7th The fact that a company which is a resident of a Contracting
State controls or is controlled by a company which is
resident of the other Contracting State, or which carries
activity (whether through a permanent establishment or otherwise) , shall not of itself
itself constitute either company a permanent establishment of the other
company.
Article 6


Income from immovable property

First Income derived by a resident of a Contracting State from immovable
property (including income from agriculture or forestry) situated in the other
Contracting State may be taxed in that other State.

Second The term "immovable property" shall have the meaning which it has under the law
Contracting State in which such property is situated. The term shall in any case
accessory to immovable property, livestock and equipment
used in agriculture and forestry, rights to which the provisions
civil law relating to property, the right to use immovable property and rights
to variable or fixed payments for the working of, or
consent to work, mineral deposits, sources and other natural resources
; ships, boats and aircraft shall not be regarded as immovable property.

Third The provisions of paragraph 1 shall apply to income derived from the direct use, letting
or any other form of immovable property.

Fourth The provisions of paragraphs 1 and 3 shall also apply to the income from immovable property
enterprise and to income from immovable property used for the performance of independent personal
.
Article 7



Business Profits
First The profits of an enterprise of a Contracting State shall be taxable only in that
State unless the enterprise carries on business in the other Contracting State
through a permanent establishment situated therein.
If the enterprise carries on business in this manner may be profits of the enterprise
taxed in the other State but only to the extent to which the
attributable to that permanent establishment.

Second If an enterprise of a Contracting State, carries on business in
other Contracting State through a permanent establishment situated therein
located, attributed to subject to the provisions of paragraph 3
in each Contracting State to that permanent establishment the profits which it might be expected
make if it were a separate enterprise engaged in 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.

Third In determining the profits of a permanent establishment is permitted to deduct the cost
company incurred for the purposes of the permanent establishment, including
management expenses and general administrative expenses so incurred, whether
incurred in the State in which the permanent establishment is situated, or elsewhere.

Fourth If in a Contracting State to determine the profits
be attributed to a permanent establishment on the basis of apportionment of the total profits of the enterprise
its various parts, the provisions of paragraph 2 to
Contracting State from determining the profits to be taxed by the usual
division; The method of apportionment must, however, be such that
result was in line with the principles set out in this article.

Fifth Nepřičtou permanent establishment with no profit on the basis of the fact that
mere purchase of goods for the enterprise.

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

Preceding paragraphs shall be fixed each year in the same way, if
there is not sufficient reason to the contrary.

7th Where profits include items of income which are dealt with separately in
other articles of this agreement will not affect the provisions of those Articles
provisions of this Article.
Article 8

International transport


First Profits from the operation of ships, road vehicles or aircraft in international traffic
shall be taxable only in the Contracting State in which it is located
place of effective management of the enterprise. For the purposes of this article
term "profits" includes income from occasional rental of ships,
road vehicles or aircraft if the rental is incidental
relating to the operation of international traffic.

Second If the place of effective management of a shipping enterprise is aboard a ship
shall be deemed to be situated in the Contracting State in which it is located
home harbor of the ship or if no such home harbor, in
Contracting State in which the operator of the ship is a resident.

Third The provisions of paragraph 1 shall also apply to profits from participation in a pool,
joint business or an international operating organization.
Article 9

Associated companies


First If

A) an enterprise of a Contracting State participates directly or indirectly in
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
a Contracting State and an enterprise of the other Contracting State
,

And in either case the two enterprises in their commercial or financial relations
bound by the terms agreed to or imposed on them
which differ from those which would be made between independent enterprises
, then any profits which would, but for those
conditions, have accrued to one of the enterprises, but by reason of those conditions
not so accrued, may be included in the profits of that enterprise and taxed
.

Second Where a Contracting State includes in the profits of an enterprise of that State and
taxes accordingly profits on which an enterprise of the other Contracting State
taxed in that other State and the profits so included are profits which would have accrued
now for the first time mentioned State if the conditions agreed upon between
enterprises had been those which would be made between independent enterprises
adjusts the second state, an appropriate amount of tax imposed on
those profits in that State. In determining such adjustment taking
due consideration to any other provision of this Agreement, and, if necessary, the competent authorities
Contracting States shall consult each other.

Third The provisions of paragraph 2 shall not apply in the case of fraud or willful neglect
.
Article 10

Dividends


First Dividends paid by a company which is a resident of a
Contracting State to a resident of the other Contracting State
may be taxed in that other State.

Second However, such dividends may also be taxed in the Contracting State in
which the company paying the dividends is a resident and according to the law
law of that State, but if the recipient is the beneficial owner
dividend tax so charged shall not exceed:

A) 5% of the gross amount of the dividends if the beneficial owner is a company (other than a
a partnership) which holds directly at least 15% of assets
company paying the dividends;

B) 15% of the gross amount of the dividends in all other cases.

This paragraph shall not affect the taxation of company profits from which dividends are paid
.

Third The term "dividends" as used in this Article means income from shares,
jouissance shares or jouissance rights, mining shares, founders' shares or other rights
with profits, with the exception of receivables as well as income from
rights to companies that are under the tax laws of the State
in which the company making the distribution is a resident, built on the same footing
income from shares.

Fourth The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends
who is a resident of a Contracting State, carries
in the other Contracting State in which the resident company paying the dividends
, industrial or commercial activity through a fixed
establishment situated therein, or performs in that other State independent personal
a fixed base situated therein, and
the holding in respect of which the dividends are paid is effectively connected

Such permanent establishment or fixed base. In this case
provisions of Article 7 or 14, depending on what goes
.

Fifth Where a company which is a resident of a Contracting State
derives profits or income from the other Contracting State, that other State
tax on the dividends paid by the company, unless such
dividends are paid to a resident of that other State or that participation ,
which the dividends are paid is effectively connected with a permanent establishment or a fixed base
which is situated in that other State, nor
subject the company's undistributed profits tax on undistributed profits, even if the dividends paid
or the undistributed profits consist wholly or partly of
profits or income arising in that other State.
Article 11

Interest


First Interest arising in a Contracting State and paid to a resident
other Contracting State may be taxed in that other State.

Second However, such interest may also be taxed in the Contracting State in
which they arise, and according to the laws of that State, but if
recipient is the beneficial owner of the interest, the tax so charged shall not exceed 10
% of the gross amount of the interest.

Third Notwithstanding the provisions of paragraph 2, interest arising in a
Contracting State and paid to a resident of the other Contracting State shall be taxable only
in that other State if such interest is paid from:

A) bonds, debentures or similar obligations of government
first-mentioned Contracting State; or

B) loans granted, refinanced, guaranteed or secured
or loans granted, refinanced, guaranteed or secured

(I) in the case of the Czech Republic, the Czech National Bank;

(Ii) in the case of Israel, the Bank of Israel.

Fourth The term "interest" as used in this Article means income from debt-claims of every kind
not secured by a lien on the property or
or not having the right to participate in the debtor's profits
particular, income from government securities and income from bonds or debentures, including premiums
and rewards associated with these securities
bonds or debentures. Penalties for late payment are not considered
interest for the purposes of this article.

Fifth The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner
interest, being a resident of a Contracting State, carries on business in the other
Contracting State in which the interest arises,
business through a permanent establishment, situated therein, or
independent personal services from a fixed base situated therein, and the debt
, of which the interest is paid is effectively connected
such permanent establishment or fixed base. In this case
provisions of Article 7 or 14, depending on what goes
.

6th It is believed that the interest arising in a Contracting State when the payer
is that State itself, a political subdivision, a local
authority or a resident of that State. If, however, the person paying the interest, whether he is
resident of a Contracting State or not, has in a Contracting State a permanent
establishment or a fixed base in connection with which the indebtedness
from which the interest is paid, and such interest is going borne by such permanent
establishment or fixed base, then such interest shall be deemed
state in which the permanent establishment or fixed base
located.

7th If the amount of interest related to the debt for which it is paid
exceeds the result of a special relationship between
payer and the beneficial owner of the interest, or even the second one keeps
with a third party, the amount would have been agreed upon by the payer and the beneficial owner
absence of such relationship, the provisions of this article
only on the latter amount. The amount of salary that exceeds
it will in this case remain taxable according to the laws of each Contracting State
with regard to the other provisions of this Treaty.
Article 12

Royalties


First Royalties arising in a Contracting State and paid
resident of the other Contracting State may be taxed in that other State
.

Second However, such royalties may also be taxed in the Contracting
State in which they arise, and in accordance with the law

That State, but if the recipient is the beneficial owner of the royalties
taxes, the tax so charged shall not exceed 5% of the gross amount of royalties
.

Third The term "royalties" as used in this Article means payments
any kind received as a consideration for the use or the right to use
copyright of literary, artistic or scientific work (including
cinematograph films, video and movies or
recordings for radio or television broadcasting), any patent, trade mark, design or model
, plan, software, secret formula or process
or for the use or right to use, industrial, commercial or
scientific equipment, or for information that applies to
experience acquired in the industrial, commercial or scientific.

Fourth The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner
royalties, being a resident of a Contracting State
exercised in the other Contracting State in which the royalties
arise a business through a permanent
establishment situated therein, or performs independent personal
a fixed base situated therein, and the right or
assets, of which the royalties are paid is effectively connected
such permanent establishment or fixed base. In this case the
provisions of Article 7 or 14, depending on what it is.

Fifth It is assumed that the royalties to arise in a Contracting State when the payer
is that State itself, a political subdivision, a local
authority or a resident of that State. However, if
paying the royalties, whether he is or is not a resident in a Contracting State, he has in a Contracting State
permanent establishment or fixed base in connection with which arose
obligation to pay royalties, which are borne by a permanent establishment
or fixed base, then such royalties shall
arise in the Contracting State in which the permanent establishment or fixed base is situated
.

6th If the amount of royalties that apply to the use,
right or information for which they are paid, exceeds
due to the special relationship between the payer and the beneficial owner or
which maintains the second one with a third party the amount which would have been
agreed upon by the payer and the beneficial owner in the absence of such relationship,
the provisions of this Article shall apply only to the latter amount
. The amount of the salary, the excess will be taxed in this case
under the laws of each Contracting State, taking into account
other provisions of this Agreement.
Article 13


Gains from the alienation of property

First Profits derived by a resident of a Contracting State from the alienation of immovable property
referred to in paragraph 2 of Article 6, may be taxed
in the Contracting State in which such property is situated.

Second Gains from the alienation of movable property forming part of the business assets
permanent establishment which an enterprise of a Contracting State in the other
Contracting State or movable property pertaining to a fixed base,
by a resident of a Contracting State has in the other Contracting State to
performance of professional services, including such gains from the alienation
such a permanent establishment (alone or with the whole enterprise)
or of such fixed base, may be taxed in that other State.

Third Gains from the alienation of ships, aircraft or road vehicles operated
in international traffic or movable property pertaining to the operation
such ships, aircraft or road vehicles shall be taxable only in the Contracting State
, which is located in the center of effective company management.

Fourth Gains from the alienation of shares in a company which is a resident of
Contracting State may be taxed in that State.

Fifth Gains from the alienation of any property other than that referred to in paragraphs 1
2, 3 and 4 shall be taxable only in the Contracting State of which the alienator
resident.
Article 14


Independent Personal

First Income derived by a resident of a Contracting State in respect of
profession or other activities of an independent character shall be taxable
only in that State except in cases where the following conditions may be
such income may also be taxed in the other Contracting State :

A) if he has regularly available fixed base in the other Contracting

State for the purpose of performing his activities; In this case, only
such 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 periods
exceeding in the aggregate 183 days in any twelve month period;
in this case only the income that is derived from his activities
performed in that other State may be taxed in that other State
.

Second The term "professional services" includes especially independent
scientific, literary, artistic, educational or teaching activities as well as
independent activities of physicians, dentists, lawyers, engineers, architects and accountants
.
Article 15

Occupation


First Salaries, wages and other similar remuneration derived by a resident of a Contracting State
respect of an employment shall be subject to the provisions
Articles 16, 18, 19, 20 and 21, be taxable only in that State unless the employment is not
exercised in the other Contracting State. If the employment is so exercised
they may be received rewards for them taxed in that other State
.

Second Remuneration which a resident of a Contracting State in respect of an employment exercised
in the other Contracting State shall
notwithstanding the provisions of paragraph 1 shall be taxable only in the first-mentioned State if:

A) the recipient is present in the other State for a period or periods exceeding in the aggregate
183 days in any twelve-month period, and

B) the remuneration is paid by the employer or the employer who
not a resident of the other State, and

C) the remuneration is not borne by a permanent establishment or a fixed base which the employer
in the other State.

Third Notwithstanding the preceding provisions of this Article, remuneration
respect of an employment exercised aboard a ship, aircraft or
road vehicle in international traffic, be taxed in the Contracting State in which it is situated
place of effective management of the enterprise.
Article 16

Royalties


Fees and other similar remuneration derived by a resident of a Contracting State
his capacity as a board member or another similar organ of a company,
which is a resident of the other Contracting State may be taxed in that other State
.
Article 17

Artists and athletes


First Income derived by a resident of a Contracting State as an entertainer
such as theater, film, radio or television
artist or a musician, or as a sportsman, from such person
activities performed in the other Contracting State may be
regardless of the provisions of Articles 14 and 15, be taxed in that other State.

Second If revenues from personal activities exercised by an entertainer or an athlete
accrues not to the entertainer or athlete himself but to another
person, that income may, notwithstanding the provisions of Articles 7, 14 and 15
taxed in the Contracting State in which entertainer or athlete performs
its activities.

Third Revenue generated entertainer or athlete who is a resident of a Contracting State
from activities personally exercised in the other Contracting
State shall, notwithstanding the provisions of paragraphs 1 and 2
taxable only in the first-mentioned State if activities in the other State are paid
wholly or substantially from public funds mentioned State
including its political subdivisions or local authorities, and those
activities are carried out under a bilateral cultural agreement between these
Contracting States.
Article 18

Pensions


Pensions and other similar remuneration paid in consideration of past employment
resident of a Contracting State shall, subject to the provisions of paragraph 2 of Article
19 taxable only in that State.
Article 19

Public functions


First

A) Remuneration, other than a pension, paid by a Contracting State or a
subdivision or a local authority thereof to an individual in respect of services rendered to that
State or subdivision or local
authority shall be taxable only in that State.

B) However, such remuneration shall be taxable only in the other Contracting State
if the services are rendered in that State and the individual who
is a resident of that State:

(I) is a national of that State; or

(Ii) did not become a resident of that State solely for the purpose of rendering those services
.

Second


A) Any pension paid by, or out of funds created a
Contracting State, political subdivision or local authority thereof,
individual in respect of services rendered to that State or subdivision or local
authority shall be taxable only in that State.

B) However, such pension shall be taxable only in the other Contracting State
if the individual is a resident and a national of that State
.

Third The provisions of Articles 15, 16 and 18 shall apply to remuneration and pensions
services rendered in connection with a business carried
a Contracting State, political subdivision or local authority of that State
.
Article 20

Students and apprentices


Payments which a student or apprentice who is or was immediately before
visiting a Contracting State a resident of the other Contracting
State and who is present in the first-mentioned State solely for the purpose of study or training
, receives for his maintenance, education or training
not be taxed in that State, provided that such payments are made to him
paid from sources outside that State.
Article 21


Teachers and researchers

Reward he receives for teaching or research for a natural person who is or
immediately before visiting a Contracting State was a resident
other Contracting State and who is present in the first-mentioned State
for the purpose of conducting research or teaching in education, will be exempt from taxation
mentioned State. This exemption will be granted after
period not exceeding two years from the date of arrival
this teacher or researcher in the country. This article shall not apply to income
from research if such research is undertaken not for public interest
but primarily for the private benefit of a specific person or persons.
Article 22

Other income


First Items of income of a resident of a Contracting State, whether they
source anywhere, not dealt with in the foregoing Articles
this Agreement shall be taxable only in that State.

Second Paragraph 1 shall not apply to income other than income from
immovable property as defined in paragraph 2 of Article 6, if
recipient of such income, being a resident of a Contracting State, carries
industrial or commercial activity in the other Contracting State
through a permanent establishment situated therein, or performs in that
other State independent personal services from a fixed base situated therein, and
the right or property in respect of which the income is paid is effectively connected
with such permanent establishment or fixed base.
In this case, the provisions of Article 7 or 14, depending on what case
.
Article 23

Avoidance of double taxation


Double taxation will be eliminated as follows:

A) in the Czech Republic:

Czech Republic, when imposing taxes on its residents
basis upon which such taxes are imposed the income which may be
under the provisions of Articles of this Agreement may also be taxed in Israel, but reduce the amount
permit tax computed on such a base an amount
equal to the tax paid in Israel. The amount by which the tax is reduced,
however, exceed that part of the Czech tax, as computed before the deduction,
which is attributable to the income which may be under the provisions of this contract
taxed in Israel

B) in Israel:

In accordance with the laws of Israel, which regulate credit
tax paid in any country except Israel tax payable in Israel, the Czech
tax paid on income from sources in the Czech Republic
offset tax payable Israel attributable to such income.
Netted amount, however, exceed that portion of Israeli tax which is attributable to
income from sources in the Czech Republic in relation to the total income
subject to Israeli tax.
Article 24

Prohibition of discrimination


First Nationals of a Contracting State shall not be subjected in the other Contracting State
any taxation or any requirement connected therewith,
which is other or more burdensome than the taxation and connected requirements
which are or may be subjected nationals of that other
State who are in the same situation. This provision shall, notwithstanding the provisions of Article 1
also apply to persons who are not residents

One or both of the Contracting States.

Second Taxation on a permanent establishment which an enterprise of a Contracting State has in
other Contracting State shall not be in that other State
favorable than the taxation of enterprises of that other State carrying on the same activities.

Third Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11
or paragraph 6 of Article 12 apply, interest, royalties and other disbursements paid
enterprise of a Contracting State to a person who is
resident of the other Contracting State deductible in determining taxable profits
this business under the same conditions as if they were
paid to a resident of the first-mentioned State.

Fourth Enterprise of a Contracting State, the capital of which is wholly or partly
directly or indirectly owned or controlled by a person or persons
resident of the other Contracting State shall not be subjected in the first
mentioned Contracting State to any taxation or any requirement
associated with it, which is other or more burdensome than the taxation and connected
obligations are or may be subjected to other similar enterprises
first-mentioned State.

Fifth The provisions of this Article shall, notwithstanding the provisions of Article 2
apply to taxes of every kind and description.

6th The provisions of this article shall not be construed to prevent a Contracting State
impose income tax offices.

7th The provisions of this article shall not be construed as obliging a Contracting State
provide residents of the other Contracting State
any personal allowances, reliefs and tax reductions for private
status or family responsibilities which it grants to its own residents.
Article 25


Limited benefits

Competent authority of a Contracting State may, after consultation with the relevant
authority of the other Contracting State, deny the benefits thereof to any person or
in relation to any transaction, if in its opinion
would provide benefits means taking Treaty contrary to its purpose.
Article 26

Mutual agreement


First If a person considers that the actions of one or both of the Contracting
States result or will result for him in taxation not in accordance with the provisions
thereof, may, notwithstanding the remedies provided by the domestic
legislation such State
present his case to the competent authority of the Contracting State of which he is a resident
if his case comes under paragraph 1 of Article 24, the Contracting
State of which he is a national. The case must be presented within three
years from the first notification of the action resulting in taxation not in
accordance with the provisions of this Treaty.

Second The competent authority shall objection be justified and
if it is not itself able to arrive at a satisfactory solution, it will try to
case decided by mutual agreement with the competent authority of the other Contracting State
so that the avoidance of taxation It is not in conformity with the contract
. Any agreement reached shall be implemented notwithstanding
time limit under national law of the Contracting States.

Third The competent authorities of the Contracting States shall endeavor to resolve by mutual agreement
difficulties or doubts that may arise regarding the interpretation or application of this Agreement
. They may also consult together for the avoidance of double taxation
in cases not provided for in the Treaty.

Fourth The competent authorities of the Contracting States may communicate with each other directly for the purpose
reaching an agreement in the sense of the preceding paragraphs. If oral
exchange of views seems advisable for reaching agreement, such exchange may take place through
views commission consisting of representatives
competent authorities of the Contracting States.
Article 27

Exchange of information


First The competent authorities of the Contracting States shall exchange information necessary for
application of the provisions of this Agreement or national laws
laws of the Contracting States concerning taxes covered by
thereof, insofar as the taxation thereunder is not
violation of this agreement. Any information received by a Contracting State shall be treated as secret
same manner as information obtained under the domestic
laws of this state or at the request of the other Contracting State
providing the information and shall be disclosed only to persons or authorities
(including courts and administrative bodies) concerned with the assessment or

Collection of the taxes covered by this Agreement,
prosecution in respect of, taxes or the determination of appeals.
Such persons or authorities shall use the information only for such purposes.
May disclose the information in public court proceedings or in judicial decisions
.

Second The provisions of paragraph 1 shall in no case be interpreted as meaning that
impose on a Contracting State the obligation:

A) to carry out administrative measures that would conflict with legal
legislation or administrative practice of that or the other Contracting State;

B) to supply information which is not obtainable under the laws or regulations
normal administration of that or of the other State;

C) to supply information which would disclose any trade, business,
industrial, commercial or professional secret or trade process, or
information, the disclosure of which would be contrary to public policy.
Article 28


Diplomats and consular officials

Nothing in this Agreement shall affect the fiscal privileges
of diplomatic or consular officials under the general rules
international law or under the provisions of special agreements.
Article 29

Entry into force


First This Treaty shall be ratified and instruments of ratification shall be exchanged as soon as possible
.

Second The contract will come into force upon the exchange of instruments of ratification and its
provisions shall apply:

A) in respect of taxes withheld at source on amounts paid on 1
January or later in the calendar year following the year in which
Agreement enters into force;

B) in respect of other taxes on income to taxes chargeable for any taxable year beginning
or after 1st January of the calendar year following
year in which the Convention enters into force.
Article 30

Termination


This Agreement shall remain in force until terminated by a Contracting State
. Each Contracting State may terminate
writing through diplomatic channels at least six months before the end of each
calendar year beginning after the expiration of five years from the date of entry into force of this Treaty
. In this case, the Agreement shall cease to apply:

A) in respect of taxes withheld at source on amounts paid on 1
January or later in the calendar year next following that in which the notice is given
;

B) in respect of other taxes on income to taxes chargeable for any taxable year beginning
or after 1st January of the calendar year following
year in which the notice is given.

Done in Jerusalem December 12, 1993 in English.

For the Government of the Czech Republic:

J. Zieleniec vr

For the Government of the State of Israel:

S. Perez vr