119/1987 Coll.



DECREE



Minister of Foreign Affairs



of 29 April 2004. October 1987



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

People's Democratic Republic of Algeria for the avoidance of double taxation

income from the exploitation of international air transport



On 18 July 2005. June 1985 was in Algiers signed an agreement between the Government of

The Czechoslovak Socialist Republic and the Government of the people's Democratic of Algeria

the people's Republic on the avoidance of double taxation of income from the use of

international air travel. Treaty has entered into force, based on the

Article 6 on the day 17. May 1987.



The Czech version of the Treaty shall be designated at the same time.



Minister:



Ing. Chňoupek v.r.



CONTRACT



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

people's Democratic Republic on avoidance of double taxation of income from

the use of international air transport



The Government of the Czechoslovak Socialist Republic



and



the Government of the people's Democratic Republic of Algeria



Desiring to conclude an agreement on avoidance of double taxation of income from

the use of international air transport,



have agreed the following:



Article 1



For the purposes of this agreement:



1. the term "Contracting State" means, as the context of the Czechoslovak

Socialist Republic or the people's Democratic Republic

Republic.



2. The expression "use of international transport" means transport by air

people, animals, goods and mail, including ticket sales and other documents

undertaken between the airports in the territory of the Contracting States in accordance with the

Agreement on air transport between the two countries.



3. the term "air" means, as the context of a legal person

public and private rights of one of the Contracting States, using the

international transport airplanes belonging to or hired by them and having

the effective centre of management in that State.



4. the term "territory" in relation to a Contracting State means a State of the territory,

territorial waters and other areas of the sea, over which the State exercises

its sovereign rights and laws in accordance with international law.



5. The expression "competent authority" means, as regards the people's

Democratic Republic, the Minister of finance or his

an authorised representative, and if it is a Czechoslovak Socialist

the Republic, the Minister of Finance of the Czechoslovak Socialist Republic or

his authorised representative.



6. the term "tax" means exhaust having been made to the State and local

administrative departments, whether there is any way to select.



7. for the purposes of the interpretation of this agreement by a Contracting State, each expression that

is not defined, it makes sense that it falls to him under the law of the State which

Adjusts the taxes to which the Agreement applies, unless the context requires

the interpretation is different.



Article 2



This agreement applies to the following air companies: in Algeria: La

sociéte National de Transport "Air Algérie" or any other

companies replacing or acting on the basis of the same permissions

as this company;



in Czechoslovakia:



Czechoslovak Airlines (la Compagnie Aérienne Tchécoslovaque), or

any other company replacing it or acting on the basis of

the same permissions as the company.



Article 3



1. on the basis of reciprocity, the firm established its real

leadership in one Contracting State in the other Contracting State shall not be subject

taxation of its income from the exploitation of international air transport

the following taxes and fees:



in Algeria:



-taxes on profits from industrial and commercial activities (limpôt sur les

' bénéfices industriels et commerciaux-B. I. C.),



-fee from industrial and commercial activities (la taxe sur ľactivité

industrielle et commerciale-T.A.I.C.);



in Czechoslovakia:



-taxes on profits.



2. Also are not subject to taxation of wages and similar payments paid by the enterprise

Contracting State employees who have the nationality of that State,

who perform their jobs in the second State where the undertaking is not

the seat of its management.



Article 4



This agreement shall apply also to any taxes identical or similar

nature, which could in the future replace or supplement the taxes and

the fees referred to in article 3.



The competent authorities of a Contracting State, if necessary, communicate changes

made in their tax legislation at the moment of their approval.



Article 5



The competent authorities of both Contracting States shall agree on a common approach and

necessary measures in determining how to apply the provisions of this

of the Treaty.



Article 6



This agreement shall enter into force as soon as the Contracting States shall communicate to the

through diplomatic channels, the formalities prescribed have been fulfilled their

further legislation.



It will be used on the income taxes on the use of international transport

achieved the undertakings referred to in article 2 by 1. January 1977.



Article 7



The Treaty shall remain in force for an unlimited period, unless one of the Governments of the

notice of termination through diplomatic channels by means of notification 6

months in advance.



In this case, the contract ceases to be used on all income taxes on

the use of international transport achieved from 1. January of the year

immediately following the expiry of this period.



In witness whereof, the duly authorized by their Governments, have signed this

the contract.



Done at Algiers on 18 July 2005. June 1985 in two original copies, each

in Czech, English, Arabic and French.



All three texts being equally authentic.



For the Government of the Czechoslovak Socialist Republic:



Jan Žižka v.r.



The Government of the people's Democratic Republic of Algeria:



Mohamed Terbeš v.r.