419/1992 Coll.
COMMUNICATION


Federal Department of Foreign Affairs

Federal Ministry of Foreign Affairs informs that on 14 March 1990
was signed in Prague treaty between the Czech and Slovak
Federal Republic and the Republic of Tunisia for the avoidance of double taxation and the prevention
Fiscal Evasion taxes on income and property.

With the Treaty approved by the Federal Assembly of the Czech and Slovak Federal Republic and
president of the Czech and Slovak Federal Republic ratified
. The instruments of ratification were exchanged in Tunis
on 25 October 1991.

Treaty entered into force by virtue of Article 28th paragraph. 2 day
25th October 1991.

Czech translation of the Treaty shall be open simultaneously.


AGREEMENT
Between the Czechoslovak Socialist Republic and the Government of Tunisia
Republic for the Avoidance of Double Taxation and Prevention of Fiscal Evasion
taxes on income and property

Government of the Czechoslovak Socialist Republic and the Government of the Republic of Tunisia

Desiring to conclude an agreement on the avoidance of double taxation and the prevention
Fiscal Evasion with respect to Taxes on Income and Property

The Agreement as follows:
Article 1


PERSONS COVERED

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


TAXES COVERED

First This Agreement shall apply to taxes on income and wealth collected in the
each of the Contracting States, irrespective of the manner levied.

Second Taxes on income and assets are considered taxes imposed on total income
property or items of income and property, including taxes on gains from the alienation
movable or immovable property, taxes on the total amounts of wages paid to businesses and
taxes on capital appreciation.

Third The existing taxes to which the Convention applies are:

A) in Czechoslovakia:

- Payment of profit;

- Profit tax;

- Payroll tax;

- Tax on income from literary and artistic activities;

- Agricultural tax;

- The tax on population income;

- House tax;

B) Tunisia:

- Corporation tax;

- Tax on the profits of industrial and commercial activities;

- The tax on profits from non-commercial activities;

- A tax on salaries and wages;

- Agricultural tax;

- Tax increase in property values;

- The tax on income from movable assets;

- Tax on income from loans, deposits, guarantees and current accounts;

- Special benefits solidarity;

- The personal benefits of the state.

Fourth This agreement also applies to tax of the same or similar kind
to be levied in the future, in addition to existing taxes or instead of them.
The competent authorities of the Contracting States shall communicate to the significant changes that will
made in their respective taxation laws.
Article 3



GENERAL DEFINITIONS
First In terms of this Agreement, unless the context otherwise requires:

A) the term "Czechoslovakia" means the Czechoslovak Socialist Republic
;

B) the term "Tunisia" means the Republic of Tunisia, including
territory belonging to the Tunisian territorial waters, where Tunisia
exercised in accordance with international law, their rights in relation to the seabed and its subsoil and their natural
sources;

C) the terms "a Contracting State" and "the other Contracting State" mean
case of Czechoslovakia and Tunisia;

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

E) the term "company" means any body corporate or other rightholders
considered for tax purposes organizational units;

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 "nationals" means:

I) all natural persons who are nationals of one
Contracting State

Ii) any legal person, partnership and association of persons
been established under the laws of a Contracting State;

H) the term "international traffic" means any transport
by a ship or aircraft operated by an enterprise
its place of effective management in a Contracting State
when the ship or aircraft is operated solely between places in the other Contracting State
;


I) the term "competent authority" means:

I) in the case of Czechoslovakia, the Minister of Finance
Czechoslovak Socialist Republic or his authorized representative

Ii) in the case of Tunisia, the Minister of Finance or his authorized representative.

Second Any term not otherwise defined shall, for the application of this Agreement by a Contracting State
meaning which it has under the law of that State
concerning the taxes to which the Convention applies, if
context otherwise requires .
Article 4


Tax residence

First The term "resident of a Contracting State" means the purposes of this contract
any person who, under the law of that State
undergone in the State of taxation by reason of his domicile, residence, place
management or any other criterion of a similar .

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

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

B) If it can not be determined Contracting State in which the person has
center of vital interests or if he has a permanent home in any
Contracting State, it is assumed that a resident of the Contracting State || | which usually resides.

C) If he has an habitual abode in both States or
in any of them, it is assumed that a resident of the Contracting State
which he is a citizen.

D) If the person is a citizen of both Contracting States or
any of them, seek to authorities of the Contracting States to regulate
question by mutual agreement.

Third If a person other than an individual under the provisions of paragraph 1 of this Article
resident of both Contracting States, it is assumed that
a resident of the State in which the place of effective management.
Article 5

PERMANENT ESTABLISHMENT


First The term "permanent establishment" means in terms of this agreement
permanent place of business through which an enterprise is wholly or partly
activity.

Second The term "permanent establishment" includes especially:

A) a place of management;

B) plant;

C) an office;

D) a factory;

E) a workshop;

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

G) a building site or assembly if it takes longer than six months.

Third A permanent establishment shall not:

A) equipment which is used only for storage, display or delivery of 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
purchasing goods or collecting information for the 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 used for enterprise solely for the purpose
advertising, providing information, scientific research or application
other activities which have a preparatory or auxiliary character.

Fourth A person acting in a Contracting State on behalf of an enterprise
second Contracting State - other than an independent agent to whom paragraph 5
- is considered "permanent establishment" in the first-mentioned State
if this State equipped with a power of attorney, which there usually
uses and which to conclude contracts on behalf of the enterprise, unless
activities of such person are limited to the purchase of goods for the enterprise.

Fifth It is not expected that the enterprise has a permanent establishment in a State
just because it carries on business through a broker, general commission
or other independent representative if
such persons are acting in the ordinary course of their business.

6th 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

Constitute either company a permanent establishment of the other.
Article 6


Income from immovable property

First Income from immovable property including income from agriculture or forestry
enterprise may be taxed in the Contracting State where the property is located
.

Second

A) Subject to the provisions of subparagraphs b) and c) the term "Real Estate
" defined in accordance with the law of the Contracting State in which the property is situated
;

B) The term "immovable property" shall in any case accessories
immovable property, and dead livestock farming and forestry businesses and
rights, which are subject to the rules of civil
related to land law enjoyment of immovable property and rights to variable or fixed payments
for the working of, or consent to work, mineral
deposits, sources and other natural resources;

C) 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 apply equally to income from immovable property
enterprise and to income from immovable property used for the performance of independent personal
.
Article 7


Profits of enterprises

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 in each Contracting State to that permanent establishment
gains that could be achieved if it were a separate
enterprise engaged in the same or similar activities under the same or similar
conditions and was completely independent in contact with the enterprise of which it is a permanent establishment
.

Third In calculating the profits of a permanent establishment, there shall be allowed as deductions expenses
incurred for the purposes of the permanent establishment, including expenses
executive and general administrative expenses, 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
that 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 the preceding paragraphs
set each year by 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


Shipping and aviation

First Profits derived from the operation of ships or aircraft in international traffic
be taxable only in the Contracting State in which the place of effective management of the enterprise
.

Second Profits from the operation of boats used in inland waterway
may be taxed in the Contracting State in which the place of effective management
company.

Third If the place of effective management of maritime or inland
cruise is aboard a ship or boat is considered to be situated in
Contracting State in which the home harbor of the ship or boat of
or not the homeport of Contracting State in which the
operator of the ship is a resident.

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

Associated Enterprises


First If

A) an enterprise of a Contracting State participates directly or indirectly
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 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 or have been stored and
which differ from those which would be made between independent enterprises
may be included in the profits of that enterprise and incorporated
consequently taxed profits that those conditions would have accrued to one of
businesses, but due
of those conditions could be accrued.

Second If the profit from which the enterprise of a Contracting State
taxed in that State, has been included in profit enterprise of the other Contracting State
consequently taxed and if the profits so included are profits which would
was achieved by now that other Contracting State if
conditions negotiated between the two companies were identical to those that
would be made between independent enterprises, make first-mentioned State
appropriate adjustment of the amount of tax levied on that profit. This measure
take with regard to the other provisions of this Agreement with respect to
type of income and, if necessary, the competent authorities of the Contracting States shall consult
this purpose.
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 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 the tax so imposed shall not exceed:

A) 10% of the gross amount of the dividends if the beneficial owner of the dividends is
company that owns at least 25% of the shares in the 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
rights certificates, mining shares, founders' shares or other rights
- with the exception of claims - participating in profits and income from other
shares in companies that are under the law
State in which the company paying the dividends is a resident
assimilated to income from shares.

Fourth The provisions of paragraphs 1 and 2 of this Article shall not apply if
actual recipient of the dividends, being a resident of a Contracting State
carries on business in the other Contracting State in which it is resident
company paying the dividends on business
through a permanent establishment situated therein, or independent
profession through a permanent establishment situated therein and the holding
which the dividends are paid is effectively connected with such permanent
establishment or permanent base. In such case the
provisions of Article 7 or Article 14.

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 dividends paid by companies outside the territory of the other State
unless such dividends are paid to a person
who is a resident of that other State or the holding in respect of which the dividends
paid is effectively connected with a permanent establishment or a fixed base
which are situated in that other State, nor subject the undistributed || | profits to a 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 person who is
resident of the other Contracting State shall be taxable only in that other State
.

Second However, such interest, except interest on loans made to one of
Contracting State may be taxed in the Contracting State in which
they arise and according to the laws of that State, but the tax so imposed can not exceed
12% of their gross amount.

Third The term "interest" as used in this Article means income from debt
any kind, not secured by a lien on the property
, providing also do not provide the right to participate in profits

Borrower and in particular, income from government bonds and debentures, including premiums and prizes
associated with these securities.

Fourth The provisions of paragraph 1 of this Article shall not apply if the beneficial
recipient of the interest, being a resident of a Contracting State, carries
in the other Contracting State in which the interest arises,
business through a permanent establishment that there
, or performs in that other State independent profession through
fixed base situated therein and the debt on which the interest
paid is effectively connected with such permanent establishment or fixed base
. In such case the provisions of Article 7 or
14, whichever the case may be.

Fifth It is believed that the interest arising in a Contracting State
if the borrower is that State itself, a political subdivision, a local authority or
person who is resident in that State. However, if the borrower
interest, whether he is or is not a resident of a Contracting State, has in a Contracting State
fixed establishment for which the loan was interest-bearing
negotiated and which are borne by such interest is assumed that these
interest to arise in the Contracting State in which the permanent establishment is situated
.

6th If the amount of interest paid, assessed with regard to
asset from which they are paid, exceeds
owing to a special relationship between the payer and the recipient or between both of them and
person, the amount which would have been agreed upon by the payer and the recipient if not
such relationship, the provisions of this Article shall apply only to that
final amount. Part of the interest, the excess will be in this case
taxable according to the laws of each Contracting State
regard to the other provisions of this Treaty.
Article 12



ROYALTIES
First Royalties arising in a Contracting State and paid
person who is a resident of the other Contracting State may be taxed
only in that other State.

Second Unlike the provisions of paragraph 1 of this Article may be
license fees referred to in paragraph 3 may also be taxed in the Contracting State in which
they arise, and according to the laws of that State, but the tax so determined not
exceed

- 5% of the gross amount of the royalties referred to in paragraph 3b);

- 15% of the gross amount of the royalties referred to in paragraph 3a).

Third The term "royalties" as used in this Article means:

A) compensation of any kind paid for the use or consent, to use
patent, trade mark, design or model, plan, secret formula or process, or
for the use or consent to use, industrial,
commercial or scientific equipment, or for information relating
on experience acquired in the industrial, commercial or scientific;
Well as compensation for technical or economic studies or for technical assistance
provided in the other Contracting State;

B) the compensation of any kind paid for the use or consent to the use
copyright of literary, artistic or scientific work including cinematograph films and
television and radio recordings.

Fourth The provisions of paragraphs 1 and 2 of this Article shall not apply if
actual recipient of the royalties, being a resident of a Contracting State
carries on business in the other Contracting State in which
royalties arise, either industrial or
business through a permanent establishment situated therein, or independent
profession through a permanent establishment situated therein and the right
or property in respect of which the royalties are paid to them
actually connected. In this case can be used
provisions of Article 7 or Article 14, depending on what it is.

Fifth If the amount of the royalties, assessed with regard to
transactions for which they are paid, exceeds a special relationship
existing between the payer and the recipient or both of them and keep
second with third parties, the amount which would
been agreed upon by the borrower to the actual recipient in the absence of such relationship, the
provisions of paragraphs 1 and 2 only to the last-mentioned amount.
Salary amount, the excess will be taxed in this case
under the laws of each Contracting State, and considering other

Provisions of this Agreement.
Article 13


Capital gains

First Gains from the alienation of immovable property, as defined in Article 6, paragraph
. 2, may be taxed in the Contracting State where the property is located
.

Second Gains from the alienation of movable property forming part of the assets
permanent establishment which an enterprise of a Contracting State in the other Contracting State
or movable property pertaining to a fixed base which the
resident of a Contracting State has in the other Contracting State to exercise
independent profession, including such gains from the alienation
such a permanent establishment (alone or with the whole enterprise)
such fixed base, may be taxed in that other State.
Gains from the alienation of ships or aircraft used in international traffic and movable property
, the operation of such ships or aircraft, but will
taxable only in the Contracting State in which they are taxed such ships, aircraft
and property in accordance with the provisions of Article 22.
3 of this contract.

Third Gains from the alienation of any other property may be taxed only in the
Contracting State of which the alienator is a resident.
Article 14

INDEPENDENT PERSONAL


Income derived by a resident of a Contracting State in respect of
profession or other independent activities shall be taxable only in that State.
However, such income will be taxed in the other Contracting State if the recipient
:

A) is usually available in the other Contracting State a permanent base for
performance of its activities; In this case, however, only to the extent that they can
such income attributable to that fixed base or

B) the duration of his stay in one or more periods in the other Contracting State
exceeds the total of 183 days in a tax year.
Article 15

JOB


First Salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect
because of paid employment may be subject
provisions of Articles 16, 18 and 19 taxable only in that State unless the employment is exercised
in the other Contracting State. If there
performed, they can 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, may be
Notwithstanding the provisions of paragraph 1 shall be taxed 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 the tax year, 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 provisions of paragraphs 1 and 2, the remuneration in respect of an employment exercised
aboard a ship or aircraft in international traffic
considered related activity executed in
Contracting State in which the location of the seat of effective management
and enterprise may be taxed in that State.
Article 16



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


ARTISTS AND SPORTSMEN

First Incomes, which receive public performers such.
Theater, film, radio and television artists and musicians, as
athletes, from their personal activities performed in the other Contracting State may be
regardless Article 14 and 15, be taxed in the State
which their activities are carried out.

Second Paragraph 1 shall not apply to income derived from one
Contracting State who receive the person referred to in paragraph 1 of its
activities performed as members of the ensemble of the other Contracting State
whose work does not pursue profit-making.

Third Paragraph 1 shall not apply to income from activities carried out under
cultural exchanges carried out on the basis of cultural
contract concluded between the Contracting States.
Article 18

GOVERNMENT


First Remuneration, including pensions, paid by a Contracting State
administrative subdivision or a local authority thereof to an individual in respect of services

Rendered to that State or subdivision or a local authority
in exercising public functions shall be taxable only in that State.

Second The provisions of Articles 15, 16 and 19 shall apply to remuneration and pensions in respect of services rendered
within the industrial or commercial activities carried out by some
Contracting State, political subdivision or local authority thereof.
Article 19

PENSIONS


Pensions and other similar remuneration paid in consideration of past employment
resident of a Contracting State may be subject to the provisions
Article 18, paragraph 1 is taxable only in that State.
Article 20


Students, trainees and apprentices

First Payments which a student or intern, or other person in apprenticeship,
who is or was immediately before visiting a Contracting State
resident of the other Contracting State and who is staying temporarily
mentioned Contracting State solely for the the purpose of education or training
receives for maintenance, education or training shall not be taxed in that State
provided it comes from sources outside that State.

Second When it comes to scholarships and remuneration from employment, on which
covered by paragraph 1, the student or trainee described in paragraph 1
be outside it is entitled to the enjoyment of the same exemptions, reliefs or reductions
taxes as a resident of the state in which it resides.
Article 21


OTHER REVENUE

Income of a resident of a Contracting State, which are expressly
not discussed in previous articles of this Convention may be
taxable only in that State.
Article 22



PROPERTY
First Real Estate within the meaning of Article 6, paragraph 2, may be taxed in
Contracting State in which such property is situated.

Second Movable property, which is the operating assets of a permanent establishment or undertaking
pertains to a fixed base used for the performance of
profession, may be taxed in the Contracting State in which it is placed
permanent establishment or fixed base.

Third Ships and aircraft used in international traffic, as well as chattel
used for their operation shall be taxable only in the Contracting State
which houses the actual management of the enterprise.

Fourth All other elements of capital of a resident of a Contracting State
be taxable only in that State.
Article 23



ELIMINATION OF DOUBLE TAXATION
Double taxation will be avoided in the following manner:

A. In Czechoslovakia:

First If a person who is a resident of Czechoslovakia derives income
or own property, which according to the provisions of this Treaty
taxed in Tunisia, Czechoslovakia shall, subject to the provisions of paragraphs 2 and 3
such income or assets from taxation.

Second If a person who is a resident of Czechoslovakia derives income
which according to the provisions of Articles 10, 11, 12, 16 and 17 of this contract
taxed in Tunisia, Czechoslovakia shall allow to reduce the amount of tax imposed on that resident
an amount equal to the tax paid in
Tunisia. The amount by which the tax is reduced, however, exceed that part
Czechoslovak tax, as computed before the deduction is given, which is
attributable to the income which may be taxed in Tunisia.

Third Where in accordance with the provisions of this Agreement, income derived by a resident of Czechoslovakia
or property that it owns, are exempt from taxation in Czechoslovakia
may Czechoslovakia in calculating the amount of tax
remaining income or capital of such resident, use tax rate as
if the exempted income or capital had not been exempted from taxation.

B. In Tunisia:

First If a resident receives income or assets that can be
provisions of this Treaty taxed in Czechoslovakia, subtracts from Tunisia
tax which is levied on income or capital of a resident
amount equal to the tax paid in Czechoslovakia. Amount of the deduction may not exceed
part of the tax corresponding to the income which may be taxed in Czechoslovakia
.

Second Where in accordance with the provisions of this Agreement, income derived by a resident
Tunisia or property that it owns, are exempt from taxation
in Czechoslovakia, Tunisia may in calculating the amount of tax on other income or capital
such resident , apply the rate of tax as if
the exempted income or capital had not been exempted from taxation.

C. The tax, which was for a limited period remitted or reduced in any

Contracting States under the domestic legislation of that State
will be considered paid and must be deducted in the other Contracting State
a tax on the revenues.
Article 24


PRINCIPLE equal treatment

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 find themselves in the same situation.
This provision shall apply notwithstanding the provisions of Article 1, also for people who are not
residents of either Contracting State.

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.
This provision shall not be construed as obliging a Contracting State
to grant to residents of the other Contracting State any personal allowances, deductions and tax reductions
account of civil status or family responsibilities which it grants to its residents
.

Third Except where the provisions of Article 9, Article 11, paragraph 6
and Article 12, paragraph 5, interest, royalties and other disbursements paid
enterprise of a Contracting State to a resident of the other Contracting State
, deductible for determining taxable profits of that enterprise
under the same conditions as if they had been paid to a person who
resident of the first-mentioned State. Also, the financial liabilities of the enterprise
a Contracting State to a resident of the other Contracting State is permitted to deduct
for determining the taxable capital of such enterprise for
same conditions as if those obligations were to a resident of the first-mentioned State
.

Fourth Enterprises of a Contracting State, the capital of which is wholly or partly
directly or indirectly owned or controlled by a person who is
resident of the other Contracting State, or more such persons
not mentioned Contracting State to any
taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected
duties which are or may be subjected
other similar enterprises of the first-mentioned State.

Fifth The provisions of this Article shall apply notwithstanding the provisions of Article 2
to taxes of every kind and description.
Article 25


Mutual agreement

First If a person considers that the actions of one or both
Contracting States result or will result for him in taxation not in
accordance with the provisions of this Convention, irrespective of the remedies
means that the domestic law of the State
present his case to the competent authority of the Contracting State of which the
resident, or if his case comes under the provisions of Article 24
paragraph 1, the competent authority of the Contracting State of which he is a national
member. The case must be presented within three years after that, when it was first announced
action resulting in taxation not in accordance with this agreement
.

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 make the case
by mutual agreement with the competent authority of the other Contracting State to
avoidance of taxation not in accordance with this agreement.
Agreement reached shall be implemented notwithstanding the limitation period under national laws
Contracting States.

Third The competent authorities of the Contracting States shall endeavor to resolve by mutual agreement
any difficulties or doubts arising as to the interpretation or application
contract.

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
views held in the Commission composed of representatives of the competent authorities of the Contracting States
.
Article 26


INFORMATION EXCHANGE

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 inconsistent with this

Contract. Information received by a Contracting State shall be treated as secret and
may be disclosed except for the taxpayer and his agent only to persons or authorities
dealing with the assessment or collection of taxes, which are
covered by this contract, or the determination of appeals
environments and appeals and judicial authorities dealing with criminal prosecution
in matters such taxes.

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 at variance with the laws or
administrative practice of that or of the other 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, industrial,
economic or professional secret or trade process, or whose
disclosure of which would be contrary to public policy.
Article 27


MEMBERS OF DIPLOMATIC MISSIONS AND CONSULAR POSTS

Nothing in this Agreement shall affect the fiscal privileges of
members of diplomatic missions and consular posts under the general rules
international law or under special agreements.
Article 28



Entry into Force
First This Treaty shall be ratified and the ratification shall be exchanged
in Tunis.

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

A) to taxes withheld at source to income paid or
granted after December 31 of the current year in which the Convention entered into force
;

B) other taxes for tax years ending after December 31
same year;

C) property taxes for the property existing on January 1 of each year
following the year in which the Convention entered into force.
Article 29

TERMINATION


This Agreement shall remain in force until terminated by a Contracting State
. Each Contracting State may terminate the contract
diplomatic channels within a period of at least six months before the end of each calendar year
after the end of the fifth year following the year in which
treaty into force.

In this case the contract will apply last:

A) to taxes withheld at source on income paid or
granted no later than 31 December of the year in which the notice is given;

B) other taxes for tax years ending before December 31
same year;

C) property taxes for the property existing on January 1 of the year in which the notice is given
.

IN WITNESS WHEREOF, the undersigned, being duly authorized, have signed this agreement
.

Done in Prague on 14 March 1990 in duplicate in the French
.
For the Government


Czechoslovak Socialist Republic:

J. Dienstbier vr
For the Government


Republic of Tunisia

N. Boujellabia vr