Treaty On Avoidance Of Double Taxation With Greece

Original Language Title: Smlouva o zamezení dvojího zdanění s Řeckem

Read the untranslated law here: https://portal.gov.cz/app/zakony/download?idBiblio=38144&nr=98~2F1989~20Sb.&ft=txt

98/1989 Coll.



DECREE



Minister of Foreign Affairs



of 19 December 2003. July 1989



the Agreement between the Government of the Czechoslovak Socialist Republic and the Government

The Hellenic Republic for the avoidance of double taxation and prevention of tax evasion

with respect to taxes on income



On 23 December 2005. October 1986 in Athens was signed between the Government of

The Czechoslovak Socialist Republic and the Government of the Hellenic Republic on the

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

income.



With the Treaty, expressed its approval of the Federal Assembly of the Czechoslovak

the President of the Czechoslovak Socialist Republic and the Socialist

the Republic has ratified it.



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

May 23, 1989.



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



Minister:



JUDr. Mr v.r.



CONTRACT



between the Government of the Czechoslovak Socialist Republic and the Government of the Hellenic

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

taxes on income



The Government of the Czechoslovak Socialist Republic and the Government of the Hellenic Republic



Desiring to conclude an agreement on avoidance of double taxation and the prevention of

fiscal evasion with respect to taxes on income,



have agreed as follows:



Article 1



The person to which the contract relates



This agreement shall apply to persons who are resident or established in

one or both of the Contracting States (residents).



Article 2



The tax, to which the contract relates



1. this agreement applies to income tax levied for the benefit of

each of the Contracting States, its subdivisions or local authorities,

whatever way to select any.



2. the following shall be considered income taxes taxes levied on total income, or from

parts of income, including taxes on profits from the alienation of movable or immovable

property and taxes on the increment value.



3. Current taxes, to which the contract relates are:



and in the Czechoslovak Socialist Republic):



1) the income tax;



2) payroll tax;



3) income tax on the literary and artistic activities;



4) tax farming;



5) income tax the population;



6) domestic tax



(hereinafter referred to as "Czechoslovak tax");



(b)) in the Hellenic Republic:



1) tax on income of individuals;



2) income tax of legal entities;



3) post gave organisations established in accordance with the gross proceeds of

buildings



(hereinafter referred to as "Greek tax").



4. This agreement shall also apply to the same or a similar kind of tax,

which are levied after the signature of this agreement, in addition to the current taxes or

instead of them. The competent authorities of the Contracting States shall, at the end of each year

shall communicate the significant 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 "Greece" means the Hellenic Republic and in terms of geographical

includes the territory of the Hellenic Republic and the part of the seabed and its subsoil under the

The Mediterranean Sea, over which the Hellenic Republic exercises its sovereign

rights in accordance with international law;



(b)), the term "Czechoslovakia" indicates the Czechoslovak Socialist

Republic;



(c)) the terms "a Contracting State" and "the other Contracting State" mean respectively according to the

the case of the Czechoslovak Socialist Republic and the Hellenic Republic;



(d)) the term "person" includes natural persons, companies and any other

an Association of persons;



(e)) the term "company" means the person or business departments, the bearer of the

Rights considered for taxation purposes under the organizational bodies;



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

State "means the enterprise carried on by a person residing or established in

a Contracting State, or enterprise carried on by a person residing

or registered office in the other Contracting State;



(g)) the term "nationals" means:



1. all natural persons who are nationals of one of the

Contracting State,



2. all legal persons, partnerships and associations of persons who

have been set up under the law in force in a Contracting State;



h) the term "international traffic" means any transport

undertaken by an aircraft which is operated by an undertaking whose place of

effective management is located in a Contracting State, or a boat, that

is registered or provided with documents in one Contracting State, if the

ship or aircraft not operated only between places in the other Contracting

State;



I) the term "competent authority" means:



1. in the case of the Hellenic Republic the Minister of finance or his authorised

representative;



2. in the case of the Czechoslovak Socialist Republic, the Minister of finance

The Czechoslovak Socialist Republic or by his authorised representative.



2. each expression that is not otherwise defined, the application of this

the contract to the Contracting State, meaning that it has under the law of that

the State, which regulates the taxes covered by this agreement, unless

the link does not require a different interpretation.



Article 4



Tax residence



1. the term "resident of a Contracting State" means within the meaning of this

of the Treaty, any person who, under the law of that State, subject to the

that State taxation because of their place of residence, permanent residence, place of

management, or any other similar criteria. This term, however,

does not include persons who are subject to tax in that State, only from the

because income from sources in that State.



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

both of the Contracting States, the position of the specified as follows:



and it is assumed that) this person is resident in that Contracting State in

which he has a permanent home. If he has a permanent home in both Contracting States,

It is assumed that it is resident in that Contracting State for which the

enhanced personal and economic relations (Centre of vital interests).



(b)) if it cannot be determined, the Contracting State in which the person has

the Centre of their vital interests or if it does not have a permanent home in no

Contracting State, it is assumed to be a resident in that Contracting State,

in which usually resides.



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

in any of them, it is assumed to be a resident in that Contracting State,

which he is a citizen.



d) if that person is a national of both Contracting States or

any of them, the competent authorities of the Contracting States to modify

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, that is resident in

the State in which the place of effective management.



Article 5



Permanent establishment



1. the term "permanent establishment" within the meaning of this Treaty indicates the Permanent

device for business, through which the undertaking carries out completely

or part of their activities.



2. the term "permanent establishment" includes especially:



and instead of keeping);



(b)) race;



(c));



(d) a factory;)



e) a workshop;



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

benefits of natural resources.



3. A building site or installation, or install a device, if you insist

For more than 9 months.



4. Notwithstanding the preceding provisions of this article, the term "permanent

establishment "does not include:



and) device that is used only for storage, display or

the delivery of goods or merchandise 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) durable equipment for the business, which is used only for the purpose of

purchase of goods, or collecting information for the enterprise;



e) durable equipment for the business, which is used only for the enterprise

the implementation of other activities which have a preparatory or auxiliary

character;



(f)) for business durable equipment used exclusively for the combination of activities

referred to in paragraphs a) to (e)), provided that the resulting activity

durable equipment resulting from this combination is preparatory or auxiliary

character.



5. a person acting in a Contracting State on behalf of an undertaking of the second

Contracting State-other than an independent agent, which is subject to

paragraph 6-is considered as a ' permanent establishment ' in the first-mentioned State,

If it is in this State, equipped with power of Attorney, which there usually

uses and which allows her to enter into contracts on behalf of the firm, unless the

the activities of this person is not restricted to purchases of goods for the company.



6. the company is not expected to have a permanent establishment in a Contracting

the State just because it carries out its activities through

a broker, General Commission agent or any other agent of an independent,

If these persons are acting within their proper operation.



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

State, controlled by the company or is controlled by a company which is

a resident of the other Contracting State, or which carries on there

activity (whether through a permanent establishment or not), does not make itself

each other from any of this company a permanent establishment of the other company.



Article 6



Income from immovable property



1. the income received by a resident of a Contracting State from immovable


property (including income from agricultural and forestry holdings) located in

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



2. the term "immovable property" shall be defined in accordance with the law of a Contracting

the State in which such property is situated. This expression includes in any case

accessory to immovable property, livestock and agricultural and

forest holdings and rights, subject to the provisions of the civil law

relating to land, the right to the enjoyment of immovable property and rights to

variable or fixed salaries for mining or consent to the unfair advantage

mineral deposits, sources and other natural resources; ships, boats and

the aircraft will not be regarded as immovable property.



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

any other manner of use of immovable property.



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

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

an independent profession.



Article 7



The profits of enterprises



1. The profits of an enterprise of a Contracting State will be taxed 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 that other State, but only to the extent that it is

can be attributed 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,

spent on the objectives of the permanent establishment including expenses

management and general administrative expenses, whether incurred in the State in which the

the permanent establishment is situated or elsewhere.



4. If a Contracting State determine the gains that

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

the profits of the enterprise to its various parts, does not preclude the provisions of paragraph 2, to

the State has set the profits to be taxed by the usual

the Division; the method used for distribution of profits must, however, be such that the

the result was 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

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

There are insufficient grounds for a different procedure.



7. where profits include receipts, which are dealt with separately in the

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

the provisions of this article.



Article 8



Shipping and air transport



1. Profits from the operation of aircraft in international traffic will be taxed at only

in the Contracting State in which the effective centre of management is located

of the business.



2. Profits from the operation of ships in international traffic will be taxed only in the

the Contracting State in which the ships are registered or in which the

released their documents.



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

the joint operation or to other international operating organization.



Article 9



Associated enterprises



If



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

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



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

the assets of the enterprise of a Contracting State and enterprise of the other Contracting

State,



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

financial relations terms that agree or they were

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

businesses are independent, they can be incorporated into the profits of this business and

as a result, taxed profits, that without these conditions would have been

accrued to one of the businesses, which, however, due to the following conditions

could not be achieved.



Article 10



Dividends



1. dividends paid by a company which is resident in the same

Contracting State, to a person who is resident in the other Contracting State,

shall be taxable in both Contracting States.



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

jouissance shares or profit participation certificates, kuksů, founders, shares

or other rights-with the exception of claims-with profit and revenue

of the other shares in the companies that are under the law of

States in which is a company that pays dividends is resident,

built on a par with the income from the shares.



3. The provisions of paragraph 1 shall not apply where the actual recipient

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

the other Contracting State in which the resident company paying

dividends, industrial or commercial activity through a fixed

the establishment, which is located there, or independent profession

through a permanent base located there, and if the participation, for the

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

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

Article 7 or article 14.



4. Where a company which is resident in 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 person who is a resident in this second

State, or that participation, for which dividends are paid, really belongs to

to a permanent establishment or a fixed base, which are located in the

other State, nor subject the company's undistributed profits tax

retained earnings, even if the dividends paid or the undistributed profits

consists wholly or partly of profits or income realised in this

the second State.



Article 11



Interest



1. interest arising in a Contracting State and paid to the person who

is resident in the other Contracting State, may be taxed in that other

State.



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

where is their source, according to the laws of that State,

However, if the recipient is the beneficial owner of the interest, the tax so

imposed shall not exceed 10% of the gross amount of the interest.



The competent authorities of the Contracting States shall determine by mutual agreement the way

the application of this restriction.



3. Notwithstanding the provisions of paragraph 2, interest arising from a loan

provided by the Government of a Contracting State, or by the Bank, or any

other institutions in the name of or on behalf of the Government, will be subject to

only taxation in the Contracting State in which the recipient is a resident.



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

any kind, secured and not secured the right to

real estate or supplement about participation in the debtor's profits, and in particular income

from government bonds and debentures, including premiums and prizes related to the

those securities, bonds or debentures.



Penalty for late payment for the purpose of this article is not considered

the interest.



5. The provisions of paragraphs 1 and 2 shall not apply if the recipient of the interest,

that is resident in a Contracting State, carries on business in the other Contracting

State in which they have interest source, industrial or commercial activity

through a permanent establishment situated therein, or independent

the profession through a permanent base located there, and if

the claim from which the interest is paid, it actually binds to that permanent

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

the provisions of article 7 or article 14.



6. It is anticipated that interest to arise in a Contracting State,

If the payer is that State itself, its governing body, local

the authority or person who is a resident in this State. However, if the

the payer, whether he is or is not a resident in a Contracting State, has in the

a Contracting State a permanent establishment or a fixed base in the

connection with which the indebtedness on which the interest is paid, and

that this interest carries to its detriment, it is assumed that such interest should

a source in the Contracting State in which the permanent establishment or a permanent

the base is located.



7. If the amount of the interest, having regard to the debt, of which

they are paid, exceeds the due to the special relationship between the

the payer and the actual recipient of the interest, or that one or the other with

third parties, the amount which would have been had given the payer with the actual

the recipient, if it wasn't for such relationship, the provisions of this

article just on this last-mentioned amount. The amount of the salaries that it

exceeds, in this case, may be taxed in accordance with the legislation of the

Each Contracting State and taking into consideration other provisions of this

of the Treaty.



Article 12



License fees




1. Royalties arising in a Contracting State and paid

a person who is resident in the other Contracting State, may be taxed in the

that other State.



2. the royalties and licence fees referred to in paragraph 3a) can be taxed, however, also

in the Contracting State in which it is their source, according to the legal

the laws of this State. The tax thus determined, however, cannot exceed 10% of the

of the gross amount of the royalties.



The competent authorities of the Contracting States shall determine by mutual agreement the way

the application of this restriction.



3. the term "royalties" as used in this article means a refund

any kind of paid for the use of or consent to the use of:



and) patent, trade mark, design or model, plan, secret formula

or manufacturing process or industrial, commercial or scientific

equipment, or for information relating to experience gained in the

the field of industrial, commercial or scientific;



(b)) a copyright for literary, artistic or scientific

including cinematographic and tv films.



4. The provisions of paragraphs 1 and 2 shall not apply if the recipient of the license

the charges, which is resident in a Contracting State, carries on business in the

the other Contracting State in which the royalties the source, either

industrial or commercial activity through a permanent establishment,

that is placed there, or independent profession through a permanent

the base located there, and the right or property, which give rise to

royalty are actually associated with them. In this case,

can be applied to the provisions of article 7 or article 14.



5. It is assumed that the licence fees have a source in a Contracting

State when the payer is that State itself, its governing body, local

the authority or person who is a resident in this State. However, if the

the payer of the royalties, whether he is or is not a resident in any

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

a permanent base in connection with which the obligation was established on the basis of

the license fees are paid, and who is to his detriment these license

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

the Contracting State in which the permanent establishment is situated.



6. If the amount of the royalties, having regard to

the performance for which they are paid, exceeds as a result of special relationship

existing between the payer and the actual recipient, or that one even

the second keeps with third parties, the amount which would have been had given the debtor

to the actual recipient, if it wasn't for such relationships, the

the provisions of this article to the last-mentioned amount. The amount of the

the salaries that it exceeds, in this case will be taxed according to the legal

the laws of each Contracting State and taking into account other

the provisions of this agreement.



Article 13



Gains from the alienation of property



1. the profits that a resident of a Contracting State receives from the alienation

immovable property, which is defined in article 6 and which is located in

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



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

the establishment, by an enterprise of a Contracting State in the other Contracting

State, or movable property, which belongs to the permanent base

a resident of a Contracting State has in the other Contracting State for the performance of

the independent professions, including such gains from the alienation of realised

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

such permanent base, may be taxed in that other State.



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

and movable property, that serves the operation of such ships or aircraft,

will be taxed only in the Contracting State in which they are taxed income from

such ships or aircraft, in accordance with the provisions of article 8 thereof.



4. Gains from the alienation of property, other than that referred to in paragraphs 1,

2 and 3, may be taxed only in the Contracting State in which the alienator

resident.



Article 14



An independent profession



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

profession or other independent activity, will be taxed only in that State,

If the person concerned does not usually available in the other Contracting State a permanent

the base for the performance of its activities. If the available such a permanent

base, may be taxed in the other State revenue, but only to the

the extent to which it is attributable to that fixed base.



2. The expression "liberal profession" includes especially independently carried out by the

the activities of the scientific, literary, artistic, educational or teaching,

as well as the independent activities of physicians, lawyers, engineers,

architects, dentists and accountants.



Article 15



Employment



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

the State is receiving due to paid employment, they may be subject to

the provisions of articles 16, 18 and 19 to be taxed only in that State, if the

employment is exercised in the other Contracting State. If there is

employment exercised, can be taxed for them received rewards in this

the second State.



2. remuneration which a resident of a Contracting State is receiving because of the

paid employment exercised in the other Contracting State, may be

Notwithstanding the provisions of paragraph 1, be taxed only in the first-mentioned State,

If:



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

shall not exceed in the aggregate 183 days in the tax year, 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) a permanent establishment or a fixed base, which has

employer in the other State.



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

received due to paid employment exercised aboard a ship or

aircraft in international traffic are taxed only in the Contracting State in which the

are taxed income of such ships or aircraft, in accordance with

the provisions of article 8 thereof.



Article 16



Royalties



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

he receives as a member of the Board of Directors of a company which is a resident in the second

a Contracting State may be taxed in that other State.



Article 17



Artists and athletes



1. the revenue paid by residents of a Contracting State, as

to the public, such as performers. Theatre, film,

radio and television artists, and musicians or athletes, from its

the activities carried out in person in the other Contracting State, may be without

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



2. If the income from the activity that you personally carries out an athlete or

the artist, artists or athletes do this himself, but to another person,

This revenue may be, notwithstanding the provisions of articles 7, 14 and 15

taxed in the Contracting State in which an artist or an athlete performs

their activity.



3. the revenue of the activities defined in paragraph 1, regardless of the

the provisions of the preceding paragraphs shall be exempt from taxation in the Member State

which such activities if these activities

they perform within the framework of cultural agreements concluded between the Contracting States.



Article 18



Board



Pensions and other similar salaries paid by reason of past employment

a resident of a Contracting State, may be subject to the provisions

Article 19, paragraph 2. 2 taxed only in that State.



Article 19



Public function



1.



and, other than) the remuneration, pension paid by one Contracting State, an administrative

Department or local authority of that State, of a natural person for services

proving this State, its administrative department or local authority

may be taxed only in that State.



(b) However, Such remuneration) will be taxed only in the other Contracting State,

If the services are performed in that State and the recipient, which is

a resident of this State



(i) is a citizen of that State, or



(ii) resident in that State only because of these services.



2.



and Pension paid by one) Contracting State, an administrative department or

the local authority of that State either directly or from the funds, which have established,

the physical person for services rendered to that State, administrative body or

the local authority may be taxed only in that State.



(b) However, Such pension) will be taxed only in the other Contracting State,

If the recipient is a resident and citizen of this State.



3. the provisions of articles 15, 16 and 18 shall apply to remuneration and pensions for services

proven in the context of industrial or commercial activities carried out by some

Contracting State, an administrative department or local authority of that State.



Article 20



Professors and students



1. The rewards that a resident of a Contracting State receives for study

or research activities at the high school or university teaching,

Research Institute or other similar establishments for higher education for

temporary residence not exceeding two years in the other Contracting State,

will not be taxed in that other State.



2. Salaries, which a student or trainee, who is or has been

immediately prior to their arrival in a Contracting State a resident of the


in the other Contracting State and who is present in the first-mentioned State only

for the purpose of study or training, to cover the costs of nutrition, studies

or training, shall not be taxed in that State, provided that it is

from sources outside that State.



Article 21



Other income



1. the income of a person who is resident in a Contracting State of which the

specifically not dealt with in the foregoing articles of this agreement, may be

taxed only in that State.



2. The provisions of paragraph 1 shall not apply to income, other than income from

immovable property within the meaning of article 6 (1). 2 If the recipient

of such income, being a resident in a Contracting State, carries on business

in the other Contracting State having an industrial or commercial activity

through a permanent establishment situated therein, or independent

the profession through a permanent base located there, and the right or

assets for which the revenue, actually belong to this permanent

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

the provisions of article 7 or article 14.



Article 22



Provisions on the exclusion of double taxation



1. In Greece double taxation will be avoided in the following manner:



If a person who is resident in Greece, is receiving income, which may

in accordance with the provisions of this agreement, be taxed in Czechoslovakia,

This allows Greece to a resident of deduct an amount corresponding to the tax

paid in Czechoslovakia from its tax liability.



The amount to be deducted, however, it cannot exceed the proportion of the tax, calculated

before it is executed, the deduction which is attributable to the income which may

be taxed in Czechoslovakia.



2. In the UK will be the Elimination of double taxation in the following way:



and if the person) is resident in Czechoslovakia, is in receipt of income

that may be in accordance with the provisions of this Treaty are taxed in Greece, cut the

Czechoslovakia was subject to the provisions referred to in subparagraph (b)) of this

paragraph this revenue from taxation, but may, in calculating the amount of tax from the

other income of that person, apply the rate of tax which would have been applied,

If revenue has not been exempted from taxation.



(b)) may, when depositing taxes Czechoslovakia to persons who are resident in the

Czechoslovakia, include in the tax base income, which may be based on

the provisions of articles 10, 11, 12, 16 and 17 of this agreement also taxed in the

Greece, but enables to reduce the amount of tax calculated on the basis of this

amount equal to the tax paid in Greece. The amount by which the tax

reduced, however, shall not exceed such a part of the Czechoslovak tax calculated before

the reduction, which rather falls on income which, in accordance with the

the provisions of articles 10, 11, 12, 16 and 17 of this agreement may be taxed

in Greece.



3. If, under the laws of one Contracting State shall be granted partial

or exemption from the taxes to which this agreement applies, the

the other Contracting State for the purpose of calculating the amount of the deduction allowed

the tax, as indicated in the previous paragraphs, this tax is considered

paid.



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 duties associated with him,

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

which they are or may be subjected to the nationals of that

the second Member State, who are in the same situation. This provision shall apply without

Notwithstanding the provisions of article 1, also for persons who are not residents

one or both of the Contracting States.



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

This provision shall not be construed as an obligation of a Contracting State,

admitting to residents of the other Contracting State personal credits, deductions and

the tax reduction because of the status or family obligations that

grants to its residents.



3. If you will apply the provisions of article 9, article 11, paragraph 2. 7 and

Article 12, paragraph 1. 6, interest, royalties and other expenses paid

the enterprise of a Contracting State to a person who is a resident in the second

a Contracting State to determine the deductible taxable profits of that

the undertaking under the same terms as would have been paid to a person who is

a resident of the first-mentioned State.



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

directly or indirectly owned or controlled by a person who is

a resident of the other Contracting State, or a larger number of such persons,

will not be subjected in the first-mentioned State to any taxation or

the obligations associated with him, which is other or more burdensome than the taxation

and with it the obligation to which they are or may be subjected to

other similar businesses for the first-mentioned State.



5. the provisions of this article shall apply notwithstanding the provisions of article

2 the taxes of any kind and name.



Article 24



Deal with cases on the way of the agreement



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

of the Contracting States result or will result for her, to taxation, which is not in

accordance with the provisions of this Treaty, may, independently of the provisions

the resource provides the national law of those States,

present your case to the competent authority of the Contracting State of which he is

a resident, or if her case falls under the provisions of article 23, paragraph 1.

1, the competent authority of the Contracting State of which he is a national.

The case must be presented within two years after the first

announced measures to taxation not in accordance with this

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 make the case

edited by agreement with the competent authority of the other Contracting State, so that the

avoid taxation which is not in conformity with this agreement. Achieved

the agreement will be made without regard to the limitation of in accordance with national

the laws of the Contracting States.



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

the agreement any difficulties or doubts arising out of the interpretation or

application of the Treaty. They may also consult in order to avoid

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

opinions held within the Commission, composed 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 the information necessary

for the application the provisions of this agreement or of national laws

regulations of the Contracting States shall apply to the taxes which are the subject

This agreement, if the taxation thereunder is not contrary to the provisions of this

the Treaty. Exchange of information is not restricted by article 1. Information received

a Contracting State will be kept secret, as well as information

adopted in accordance with the national legislation of that State and may be

disclosed only to persons or authorities (including courts and administrative authorities), which

dealing with the charge of the assessment or collection of the taxes covered by this

the contract, the enforcement or prosecution in case of such taxes, or

decisions on appeals. Such persons or authorities shall use the

such information only for such purposes. They can apply this information

in public court proceedings or in judicial decisions.



2. The provisions of paragraph 1 shall not be in any way interpreted as

store the Contracting State the obligation:



and management measures) to conduct that would violate the law or

the administrative practice of that or of the other State;



(b)) to divulge information that could not be obtained on the basis of the legal

regulations or in a normal administrative procedure of this or of the other State;



(c)) to divulge information which would have revealed the commercial, industrial,

economic or trade secret or trade process, or whose

communication would be contrary to public policy.



Article 26



Diplomatic and consular officers



No provision of this Agreement shall not affect the tax privileges, which

It is for the diplomatic and consular officials under the General rules of

international law or on the basis of specific agreements.



Article 27



Entry into force of



1. the Governments of the Contracting States shall notify each other that the constitutional requirements for

entry into force of the Treaty are met.



2. the contract shall enter into force on the day of the later notification referred to in

paragraph 1 and its provisions shall take effect in both Contracting States

on income for each tax year beginning with 1. January or later

calendar year following the year in which the agreement

the validity of.



Article 28



Notice of termination



This agreement shall remain in force until denounced by one

Contracting State. Each State party may terminate the contract

through diplomatic channels, within a period of at least six months before the end of each

of the calendar year.




In this case, the contract ceases to apply, both Contracting States

on income for each tax year beginning with 1. January or later

the calendar year following the year in which the notice of termination has been given.



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



Given in duplicate at Athens on 23 June. October 1986 in English

language.



For the Government of the Czechoslovak Socialist Republic:



Ing. Bohuslav Chňoupek v.r.



For the Government of the Hellenic Republic:



Karolos Papoulias v.r.