49/1979 Sb.
DECREE
Minister of Foreign Affairs
of 21 June 1999. February 1979
Treaty on avoidance of double taxation of income and assets of legal entities
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
Socialist Republics
On 19 December. May 1978 was in Ulan Bator signed an agreement for the avoidance of
double taxation of income and assets of legal entities 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 April 2005. November 1978 in the Secretariat
The Council for mutual economic assistance, the depositary of the Treaty.
Treaty has entered into force, pursuant to article XI of the day 1. January
on this day in 1979 and entered into force for the Czechoslovak
Socialist Republic of Vietnam.
Czech translation of this Agreement shall be delivered at the same time.
First Deputy:
Ing. Book v.r.
CONTRACT
on avoidance of double taxation of income and assets of legal entities
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
perfecting 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,
starting from the principle that legal persons should not be subjected to taxation
at the same time from the same income in the territory of two or more of the Contracting Parties,
have agreed as follows:
Article. (I)
1. This Treaty shall apply to legal persons, which are located on the
the territory of the Contracting Parties.
2. If it is not possible to determine the seat of the legal person referred to in paragraph 1
This article, for its registered office within the meaning of this agreement, be treated as
the Contracting State under whose law the legal person was
set up.
3. in the event that it is not possible to determine the seat of the legal person and its tax
the position referred to in paragraph 1 and 2 of this article, resolves the issue
by mutual agreement of the competent authorities of the respective Contracting Parties.
The competent authorities within the meaning of this agreement will be the Ministry of finance
of the Contracting Parties.
Article II
This agreement shall apply to taxes, fees and other mandatory payments with
the tax nature ("taxes") levied on income and wealth
legal entities on the territory of the Contracting Parties in accordance with their laws,
regulations.
Article. (III)
Income of legal entities of each party, obtained in the territory of the other
of the parties, both directly and through branches, departments,
agencies, offices and similar bodies, be exempt from tax in the territory of
those other Contracting Parties, subject to the provisions of articles IV and V
of this agreement.
Article IV
1. The levying of taxes on immovable property of legal entities and also on income
use of the products, sales and other disposition of this property,
It is carried out in accordance with the legislation of the Contracting State in which the
property is located.
2. The levying of taxes on moveable property of legal entities and also income from
its use, sale or other disposition of this property performs the
According to the legislation of the Contracting State in which are subject to taxation
income of legal persons within the meaning of article III of this agreement.
It does not exclude the right of Contracting Parties to levy taxes on its territory
associated with the use of means of transport and with the use of land
communications.
3. For the purposes of this agreement means that:
a) immovable property is a property that is for such a recognised, in
accordance with the legislation of the Contracting State in whose territory the
property is located;
b) movable property is a property that is for such a recognised, in
accordance with the laws of the State of the seat of a legal person, that this
the property is used.
Article. In
1. the Principles and the method of levying taxes on the income and property of the international
organizations (including their branches and Department) set up by the Contracting States
or those States and organizations having headquarters in their territory shall be governed by
the founding acts of international organizations, agreed on the
the form of international agreements or specific agreements on this issue,
which will be attended by the respective parties.
2. profit international organisation that belongs to its members,
be exempt from tax in the Contracting State in which these organizations
have their headquarters. This provision shall apply even if the origin of
the said profit from other Contracting States in which they are established
the members of the relevant international organizations. The provisions of this paragraph,
does not apply in respect of the members of the international organisations of the profit States in
which these organisations have their headquarters.
Čl.VI
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
legal persons, with regard to the collection of taxes on their income and assets.
Article. (VII)
This agreement does not limit the right of Contracting Parties to collect taxes on income and
the assets of legal entities, if this is not contrary to the provisions of this agreement.
Article. (VIII)
The provisions of this Agreement shall not affect the tax concessions provided for
the General rules of international law, specific international
agreements and the relevant legislation of the Contracting Parties for
diplomatic and consular Prosecutor's Office and on the Department other
organisations and authorities.
Article. (IX)
Where provisions of the treaties in the area of corporate taxation,
that were previously concluded between the Contracting Parties, to resist
the provisions of this agreement, the provisions of this agreement will be applied.
Article. X
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.
Article. XI
This agreement is subject to ratification or approval in accordance with the legislation of the
Each Contracting Party and shall enter into force 1. January 1 of the year following the
year in which will be transmitted to the depositary of the instruments of ratification to the custody of the
or documents of approval of the contract at least five Contracting Parties. For
each of the other Contracting Parties, this Agreement shall enter into force 1.
January 1 of the year following the year in which the depositary shall transmit to the custody of the
instrument of ratification or approval of the treaty document.
Article. (XII)
1. this agreement is concluded for an unlimited period of time.
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 no later than 6 months before the end of the calendar year. In this
When the contract expires in relation to that Contracting Party
starting with 1. January of the year following the year in which it was given
notice of termination.
Article. XIII
To this agreement may, with the agreement of all Contracting Parties proceed other
States by passing the depositary of an instrument of accession. Access shall take effect
1 January the year following the year in which the depositary receives from
all participants of the contract notice on their consent with the approach.
Article. XIV
This agreement may be amended or supplemented with the consent of all the
of the Contracting Parties.
Article. XV
This Treaty is open for signature until 30. June 1978 in Moscow, Russia.
Article. XVI
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.
Done at Ulan Bator 19. May 1978, in a single original in the Russian language.
