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Minister of Foreign Affairs
of 18 May. January 1979
Treaty on avoidance of double taxation of income and assets of natural persons
between the Czechoslovak Socialist Republic, the Bulgarian folk
Republic, the Hungarian people's Republic, the Mongolian people's
Republic, the German Democratic Republic, the Polish people's
Republic, the Romanian Socialist Republic and the Union of Soviet
27 June 2002. May 1977 was in Miškovci signed an agreement for the avoidance of
double taxation of income and assets of natural persons between the Czechoslovak
Socialist Republic of Vietnam, the people's Republic of Bulgaria, the Hungarian
Republic of Algeria, the Mongolian people's Republic, German
Democratic Republic, the Polish people's Republic, Romanian
Socialist Republic of Vietnam and the Soviet Socialist Republics.
With the Treaty, expressed its approval of the Federal Assembly of the Czechoslovak
Socialist Republic and the President of the Republic has ratified it.
The ratification instrument was deposited on 30 November. December 1977 in the Secretariat
The Council for mutual economic assistance, the depositary of the Treaty.
Treaty has entered into force, pursuant to article IX on January 1. January
on this day in 1979 and entered into force for the Czechoslovak
Socialist Republic of Vietnam.
English translation of the text of the Treaty shall be designated at the same time.
Ing. Chňoupek v.r.
on avoidance of double taxation of income and assets of natural persons
The Contracting Parties
in an effort to facilitate the further extension and strengthening of the economic,
Scientific and technological and cultural cooperation between their States and in order to
improve the mechanism of their financial relationships, devizově
with a view to creating a more favourable conditions in the process of economic and
Scientific and technological cooperation and cultural exchanges,
have agreed as follows:
1. this Treaty shall apply to the natural persons who have a permanent
residence in the territory of the Contracting Parties.
2. If you cannot determine the domicile for taxation purposes in accordance with paragraph 1
This article, it will be considered a resident located within the meaning of
thereof, in the State of which a citizen is a natural person.
3. in the case where you cannot determine the domicile of a natural person referred to in
paragraph 2 of this article, resolves the question by mutual agreement
the competent authorities of the respective Contracting Parties. The competent authorities of the
within the meaning of this agreement will be the Ministry of Finance of the Contracting Parties.
This agreement shall apply to all taxes and duties levied on income and
the assets of natural persons in the territory of the Contracting Parties in accordance with their
In order to implement the principle that a natural person in respect of the same income and
assets may not be taxed at the same time on the territory of two or more Contracting
the Parties shall apply the following provisions:
and individuals posted on) the work of any authority or organization
the Contracting Parties on the trade, transport and other prosecution and
the Agency, including dopisovatelských and information centres, on the territory of the
any other Contracting Party shall be exempt from taxation in the State of residence, and
fees in respect of wages and other remuneration obtained from these
the Prosecutor's Office and agencies. This provision shall also apply in relation to the
workers international, and other international organizations [in addition to those
that are listed after the point. (b))], seconded to work in these organizations
of the States that are not state of the these organizations.
(b)) the natural persons who work in the territory of the Contracting Parties in
international economic organisations taking their activities
on the principle of chozrasčotu, are taxable and may be charged in respect of wages and
other remuneration obtained from these organizations, under the legislation of
State in which the Head Office of those organisations, if something else
It is not apparent from their constituent acts or other special arrangements.
(c)) of the natural person posted any Contracting Party on the territory of any
other Contracting Party for the purpose of providing technical assistance or
the implementation of services of a similar nature shall be exempt from taxation in the State of residence, and
charges on wages and other remuneration they receive from the institutions or
organisation of the State in which they reside. In the event that the physical
persons listed under this letter receive any remuneration from the authorities and
organizations receiving State, be taxable and may be billed these payouts,
with the exception of diets and accommodation, in accordance with the legislation of that
(d)) of the natural person going State participating on this agreement for
the purpose of the work, teaching, practice, provide consultation, etc. and in receipt of the
the salary and other remuneration directly from institutions or organizations of this State,
be taxable and may be charged in respect of such payments, with the exception of the diet and
expenditure on accommodation, according to the laws of that State.
Rates of pay and other rewards that receives natural persons listed under this
a letter from the authorities or organisations of the State of their habitual residence,
be exempt from the taxes and charges in other States participating on this
(e) the Income of natural persons) of the copyright for the use of literary,
Scientific and artistic works in the territory of any Contracting Party, and rewards
for technical inventions, scientific discoveries, industrial and General utility
patterns and improvement proposals, etc. are subject to taxes and fees according to
legislation of the State of residence of natural persons.
(f)) of the natural person going of any State involved in the this
the contract for the purpose of realisation of lectures and presentations, theatre,
concert and sports shows and similar activities in the
the receiving State shall exempt from taxes and payroll fees, fees and
other rewards that it receives from the State authorities and organisations continuous
In the case that such payments be made to natural persons, bodies or
Organization of the recipient State, tax, and may be billed according to the legal
the laws of this State.
g) taxation and levying of immovable and movable property of natural persons,
including the income from the use of this property, his inheritance, donation,
rental, sales and shift is performed according to the legislation of the State where the
the property is located.
The provisions of this Treaty shall not preclude the possibility for the interested Contracting
Parties to provide by mutual agreement or unilaterally for more relief for
natural persons in the area of taxation.
This agreement does not limit the right of Contracting Parties to tax and charge
natural persons, if this is not contrary to the provisions of this agreement.
The provisions of this Agreement shall not affect the fiscal privileges of workers
diplomatic missions and consular posts under the General rules of
of international law or under special international agreements.
1. participation in this Treaty shall affect the treaties in matters of taxation,
that were previously concluded between the Contracting Parties.
2. However, in the case where the provisions of previously concluded contracts in
contrary to the provisions of this Treaty, the provisions of this
of the Treaty.
Questions that may arise in connection with the application of this
the contract will be resolved through negotiation and consultation between ministries
finances of the parties involved.
This agreement is subject to approval in accordance with the legislation of each Contracting
Parties and shall enter into force 1. January of the year following the year in
which the depositary receives the approval of the Treaty by all the Contracting
1. this agreement is concluded for an indefinite period.
2. each Contracting Party may terminate the contract at any time after the expiry of the
the five-year period from the date of its expiry notice sent
to the depositary not later than six months before the end of the calendar year. In
this case, the agreement shall cease to be effective in relation to this contract
side, starting with 1. January of the year following the year in which the
given the statement.
To this agreement may, with the agreement of all its participants to proceed
other States passing the depositary of an instrument of accession. Access shall take
the effectiveness of the 1. January of the year following the year in which the depositary
received from all participants of the Treaty, notification of their acceptance of the
This agreement may be amended or supplemented with the consent of all the
of the Contracting Parties.
This Treaty is open for signature until 31 December 2006. July 1977 in Moscow.
This agreement shall be delivered to the custody of the Council Secretariat, mutual
economic assistance, who will perform the functions of depositary of this
of the Treaty.
Given in Miškovci (the Hungarian people's Republic) 27. May 1977 in one
original in the Russian language.
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