Appendix 1

Promise of the conclusion of the double taxation agreement between Denmark and the Czech Republic

We, by God's grace, the Queen of the Danes, do our thing.

The parliament has adopted the following law, and we know that the following law has been approved by Parliament's consent :

§ 1. The provisions of the Agreement of 25. August 2011 between the Kingdom of Denmark and the Czech Republic for the avoidance of double taxation and the prevention of tax evasion, as regards income taxes, related to the protocol, cf. Annex 1 applies to this country.

§ 2. The tax minister sets the time of the law into force.

§ 3. For people like the 14th. In November 2012, the Czech Republic and the date received pensions from Denmark which are covered by Article 18 (2). Article 21 (1) or Article 21 (1). 1, in the Agreement of 5. In May 1982 between Denmark and Czechoslovakia, on the avoidance of double taxation, in the case of income and property taxes, pension benefits may be subject to Article 17 (2). 2, in the Agreement referred to in section 1, only the subject of taxation in the Czech Republic. 1. Act. shall be applicable only as long as the person concerned remains a resident in the Czech Republic.

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Appendix 1

AGREEMENT

BETWEEN THE KINGDOM OF DENMARK AND THE CZECH REPUBLIC TO THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF TAX EVASION AS REGARDS INCOME TAXES

The Kingdom of Denmark and the Czech Republic, which wish to conclude a collective agreement to avoid double taxation and prevent tax evasion as regards income taxes,

has agreed to :

ARTICLE 1

PERSONS COVERED BY THE AGREEMENT

This Agreement shall apply to persons belonging to one or both of the Contracting Governments.

ARTICLE 2

TAXES COVERED BY THE AGREEMENT

1. This agreement shall apply to income taxes, which shall be applied on behalf of a Contracting Government or by its political subdivisions or local authorities, without regard to how they are charged.

2. As income taxes shall be considered all taxes that are paid on all income or part of the income, including taxes on the disposful or immovable property, on the total amount of gager or salaries paid by : undertakings, as well as taxes on the increase in assets.

3. The applicable taxes on which the Convention shall apply shall be :

a) In Denmark :

(i) income tax for the State ;

(ii) the municipal income tax ;

(hereinafter referred to as ' Danish tax `) ;

b) In the Czech Republic :

(i) income tax for persons ;

(ii) income tax for legal persons ;

(hereinafter referred to as "Czech tax").

The Agreement shall also apply to taxes of the same or essential nature, which, after the date of the agreement signed by the Agreement, shall be imposed as a supplement to, or rather than the taxes in force. The competent authorities of the Contracting Parties shall notify each other of significant changes made in their respective tax havens.

ARTICLE 3

COMMON DEFINITIONS

1. Except as otherwise in the context of the context, the following terms have been expressed in the following Agreement :

a) whereas the terms ' a Contracting Government ` and ' the other Contracting Government ' means Denmark or the Czech Republic, as well as the context ;

b) the term ' Denmark ` means the Kingdom of Denmark, including any area outside Denmark's territorial waters, which, in accordance with international law and according to Danish law, may or later may be designated as an area within which, Denmark may exercise sovereignty rights in the field of investigation and exploitation of natural occurrences on the seabed or in its underground waters and with regard to other activities for the purpose of investigation and economic activities ; the use of the territory ; the expression does not include the Faroes and Greenland ;

c) Whereas the term ' Czech Republic ' means the territory of the Czech Republic, the Czech Republic, the Czech Republic, after Czech law, and in accordance with international law exercising sovereignty rights ;

d) Whereas the term ' person ` includes a natural person, a company and any other group of persons ;

(e) Whereas the term "company" means any legal person or association which, in fiscal terms, is treated as a legal person ;

(f) Whereas the term ' undertaking ` shall be used in any form of vocational training ;

g) the expression ' undertaking in a Contracting Government ' and ' undertaking in the other Contracting Government ` means an undertaking operated by a person resident in a Contracting Government and an undertaking operated by a person who is a person who is a person who is a person who is a person who is a person who is or is not ; is established in the other Contracting Government ;

(h) the term ' international traffic ` means any transport by ship or aircraft used by an undertaking whose true management has its seat in a Contracting Government except where the ship or aircraft are used exclusively between seats in : the other Contracting Government ;

i) the term ' competent authority ` means :

(i) in Denmark :

the tax minister or his representative delegate ;

(ii) in the Czech Republic :

the Minister for Finance or his authorized representative ;

j) the term "citizen" means :

(i) any natural person who has the birthright of a Contracting Government ;

(ii) any legal person, any party entity or any association, which consists in force of the laws in force in a Contracting Government ;

c) the term ' business activity ` includes the exercise of free trade and of the independent nature of the establishment.

In the case of a Contracting Government of the Agreement at any time, any term not defined herein shall be attached to the importance given to it at this time in the legislation of this State for the purpose of the Directive ; shall apply to the taxes applied by the Agreement, in the form of any importance attached to the tax laws of this State in respect of the importance of this term in the other laws of this State.

ARTICLE 4

TAX HOME

1. In this Agreement, the term ' means a person belonging to a Contracting Government ' shall mean any person under the law of this State in accordance with the law of this State, due to its seat, place of residence, the seat of the seat or any other criterion ; such a character, including this State and any associated political subsection or local authority. However, this expression does not include a person who is taxable in this state only of income from sources in this state.

2. If a natural person after the provisions of paragraph 1 is established in both Contracting Governments, his status shall be determined in accordance with the following rules :

a) he shall be considered only to be the resident of the State where he has a permanent residence ; if he has a permanent residence in both States, he shall be considered only to be resident in the State with which he has the strongest ; the personal and economic relations (midpoint of its life interests) ;

b) in the event that it cannot be decided in which State he has the centre of its life interests, or if he does not have a permanent residence in any of the Member States, he shall be considered only to be the resident of the state in which he usually has a stay ;

c) if he is usually in both States or if he does not have such a residence in any of them, he shall be considered only to be the resident of the State of which he is a national ;

d) if he is a national in both States or if he is not a national of any of them, the competent authorities of the Contracting Parties shall decide the question by mutual agreement.

3. If a non-physical person, in accordance with paragraph 1 of paragraph 1, is established in both Contracting Governments, it shall be considered only to be resident in the state in which the seat of the real management is located.

Article 5

FIXED OPERATIONAL LOCATION

1. In this Agreement, the term ' firm operating location ' means a regular business location by means of an undertaking ' s business activity in whole or in part.

2. The term ' firm operating location ` shall include in particular :

a) a place where part of an undertaking is led ;

b) a branch ;

c) an office ;

d) a factory ;

(e) a workshop ;

(f) a mine, an oil or gas source, a quarry or any other place where natural occurrences are to be extracted.

3. The term ' firm operating location ` shall also include :

a) a construction site or a plant, assembly, assembly or assembly, or associated supervisory activities, but only where such space, work or business lasts for more than 12 months ;

b) the provision of services, including advice or management assistance, of an undertaking in a Contracting Government or by means of officials or other staff employed by the undertaking for the purpose, but only when the establishment of such activities ; the nature of the goods in the territory of the other Contracting Government during a period or in periods which comprise more than six months within a 12-month period.

4. An installation, drilling, or a ship used in the investigation of natural occurrences shall be considered to be a fixed operating facility, but only if the business of the business is for more than 12 months. For the purposes of this provision, activities carried out by an undertaking linked to another undertaking shall be deemed to have been exercised by the undertaking, which it is linked to, if the undertaking concerned :

a) the substance of the latter is essentially the same as that of the latter undertaking ; and

b) are employed by the same project or the same operation ;

unless the activities concerned are carried out simultaneously. For the purposes of this paragraph, undertakings shall be deemed to be connected if an undertaking is directly or indirectly involved in the management, control of or capital of another undertaking, or the same person directly or indirectly, in the management of, control of or capital of both undertakings.

Notwithstanding the previous provisions of this Article, ' regular farm ` shall be deemed not to include :

a) the use of the information solely for the purpose of storage or display of the goods belonging to the undertaking ;

b) the maintenance of a stock related to the storage or exhibition solely for the purpose of storage or exhibition ;

c) the maintenance of a stock-related undertaking solely for the purpose of processing at another undertaking ;

d) the maintenance of a fixed establishment solely for the purpose of making purchases of goods or collecting information for the undertaking ;

(e) the maintenance of a fixed establishment solely for the purpose of exercising any other undertaking of preparatory or assisting nature ;

(f) maintaining a permanent establishment solely for the purpose of exercising any combination of the activities referred to in point (a), provided that the overall business of the firm business that is the result of this combination is of preparatory work ; or a helping character.

6. If a person who is not an independent representative referred to in paragraph 7 of paragraph 7 is acting in a Contracting Government on behalf of an undertaking in the other Contracting Government, this undertaking shall be deemed to have one, irrespective of the provisions of paragraphs 1 and 2. fixed operating premises of the former state with regard to any undertaking which this person assumes for the undertaking, if this person :

a) has, and usually, exercise in this State a power of attorney to conclude contracts in the name of the operation unless this person is limited to such activity as mentioned in paragraph 5 and which, if carried out by a regular service place, would not be subject to such an operation ; make this fixed place of business under the conditions laid down in this paragraph ; or

b) does not have the power of attorney, but usually in the former state, maintain a stock from which he is regularly delivering goods on behalf of the undertaking.

7. An enterprise shall not be deemed to have a fixed operation in a Contracting Government, simply because it operates in this State by means of a mediator, a Commissioner or any other independent representative, provided that such persons act ; within the framework of their customary business activities.

8. The fact that a company belonging to a Contracting Government is a master or is to be ruled by a party belonging to the other Contracting Government or operating in this other State (either through a permanent basis ; operating location or otherwise, shall not in itself cause one company to be regarded as a firm operating location for the other.

ARTICLE 6

INCOME OF IMMOVABLE PROPERTY

1. Income, as a person resident in a Contracting Government, the acquiring of real estate (including income from country or forestry) situated in the other Contracting Government may be taxed in this other state.

2. The term ' immovable property ` shall be attached to the importance it has in the law of the Contracting Government where the property in question is situated. In all cases, the expression shall include accessories to immovable property, crew and equipment used in land and forestry, rights on which the provisions of civil rights of property are to be applied, the right of use for immovable property and the right to access ; any variable or flat-rate payments such as remuneration for the exploitation of, or the right to exploit, mining, sources and other natural occurrences ; ships and aircraft shall not be regarded as immovable property.

3. The provisions of paragraph 1 shall apply to income derived from direct use, renting or use in any form of real estate.

4. The provisions of paragraph 1 and 3 shall also apply to the income of fixed property belonging to an undertaking.

Article 7

DESERTS ON BUSINESS

1. Proceeding to be acquired by an undertaking in a Contracting Government may only be taxed in this State unless the undertaking operates in the other Contracting Government by means of a place of permanent operation. In the case of the operator of the operator, the profit of the undertaking may be taxed in the other state, but only the part thereof which may be attributed to this firm operating location.

2. If an undertaking in a Contracting Government operates in the other Contracting Government by means of a fixed operating site, then, unless the provisions of paragraph 3 result in other, in each Contracting Government to this firm, the provisions of paragraph 3 shall result in : the operation takes place the profit which it may be expected to achieve if it had been a free and independent undertaking engaged in the same or similar undertaking on the same or similar conditions, and which, in total free, relationships did business with the operation of which is a firm operating facility.

3. On the establishment of a fixed operating site, it shall be permitted to deduction costs incurred for the permanent place of operation, including the general costs incurred in management and administration, whether the costs incurred in it ; State where the fixed operating location is situated or elsewhere.

4. No profit should be carried out to a fixed operating site, simply because this operation has carried out the purchase of goods to the undertaking.

In the case of the preceding paragraphs, the profits being carried out to the permanent farm shall be replaced by the same method year, unless there is good and full reason for using a different approach.

6. If profit includes income covered by other articles of this Agreement separately, the provisions of these articles shall not be affected by the provisions of this Article.

ARTICLE 8

FORTYONLY ON INTERNATIONAL TRAFFIC

1. Continued on the operation of ships or aircraft in international traffic can only be taxed in the Contracting Government where the real management of the enterprise has its seat.

2. In the application of this Article, the profits of ships or aircraft in international traffic shall include :

a) profits by the rental of ships or aircraft with crew ("hour" or "voyage"),

b) profits by the rental of ships or aircraft without a crew (' bareboat `) ; , and

c) profit from use, availability or rental of containers (including trailers, barges and similar equipment for the carriage of containers) used for the carriage of goods.

3. The provisions of paragraph 1 shall also apply to profits by participating in a pool, a business community or an international operation organisation.

4. If the undertakings from different countries have agreed to drive ships or aircraft in international traffic through a business consortium, the provisions of this Article shall apply only to the part of the profit corresponding to that part of the consortium owned by an undertaking with a seat for the real management of a Contracting Government.

Article 9

BUNDLING UNDERTAKING

1. If

a) an undertaking in a Contracting Government, directly or indirectly, in the management of, control of, or capital of an undertaking in the other Contracting Government, or

b) the persons directly or indirectly participate in the management, control of, or capital of both an undertaking in a Contracting Government and in the other Contracting Government,

and there, in some of these cases between the two undertakings, has been agreed or set out in terms of their business or financial relations which deviate from the terms of the conditions agreed between independent undertakings, may any profit which, if these conditions had not been in place, would have fallen into account shall be taken into account for the profits of this undertaking and shall be taxed accordingly.

2. If a Contracting Government to the profit of a undertaking in the State of this State is included-and in accordance with it, the tax of the other Contracting Government has been taxed by this other State, and so on. profit margin, which would have been taken to the operation of the former State, where the terms agreed between the two undertakings, had been the same as would have been agreed between independent undertakings, shall be the same ; the second state shall make appropriate arrangements to be regulated by the amount of the tax which is calculated by the profit. The other provisions of this Agreement and the competent authorities of the Contracting Parties shall, where necessary, consult each other, shall take due account of the other provisions of this Agreement and, if necessary, consult each other.

Article 10

EXBOOTY

1. Exboots paid by a party belonging to a Contracting Government to a person belonging to the other Contracting Government may be subject to tax in this other state.

However, this yield may also be taxed in the Contracting Government where the company paying out the proceeds is based, and in accordance with the law of this State, but where the legal owner of the proceeds is established in the other Contracting Party ; Member States shall not, therefore, be more than :

a) 0%. of the gross amount of the yield if the rightful owner is a company (excluding a stakeholder) that directly owns at least 10%. the capital of the undertaking which pays the proceeds.

b) 0%. in the case of the gross amount of the yield, if the rightful owner is a pension fund or another similar institution which provides a pension scheme to which natural persons are able to be able to secure retirement benefits when such pensions are provided, or another similar institution shall provide a scheme which is tax-recognized in this other state in accordance with Article 17, paragraph 2.

c) 15%. of the gross amount of the yield in all other cases.

The competent authorities of the Contracting Parties shall lay down by mutual agreement the detailed rules for implementing these restrictions.

This paragraph shall not affect access to taxing the company of profits from which the yields are paid.

3. The term ' yield ` means the income of shares and other rights not debt claims and which gives the right to share in profit, as well as other income, which has been subject to the same fiscal treatment as a result of the same tax ; income from shares in accordance with the law of the State in which the company carrying out the payment is based.

4. The provisions of paragraph 1 and 2 shall not apply where the rightful owner of the provider, which is indigenous to a Contracting Government, operates in the other Contracting Government where the profit-paying company is indigenous, through a there is a fixed operating site and the stock holding which is based on the payment of the proceeds shall have a direct connection with such a fixed operation location. In this case, the provisions of Article 7 shall apply.

5. If a company belonging to a Contracting Government acquires profits or income from the other Contracting Government, then the other Member State may not impose any tax on the benefits provided by the company, unless the proceeds are paid ; a person resident in this other State, or unless the shareholding which is based on the payment of the proceeds, has a direct connection with a fixed farm operating in this other State, or to the company of the company, or non-unloaded profits on the company's non-defledable profits, even though it is : derive profit or not, wholly or partially, of profit or income derived from that other state.

Article 11

INTERESTERS

1. Interesters originating from a Contracting Government and owned by a person resident in the other Contracting Government may only be taxed in this other state.

2. The term ' interest ` means in this Article income of debt claims of any kind, whether they are protected by the immovable property or not, and whether they contain a right to a proportion in the debtor's profit or not, and in particular the income of : State debts and the income of debt securities or depreciation, including agiobelation and gains associated with such debt certificates, bonds or depreciation. Penalty rates for late payment shall not be regarded as interest in relation to this Article. The term 'interest' does not include any element of income deemed to be the benefit of the yield in accordance with Article 10, paragraph 3.

3. The provisions of paragraph 1 shall not apply where the rightful owner of the interest belongs to a Contracting Government, operates in the other Contracting Government of which interest is derived from the interest of the interest of the interest of the interest of the interest of the interest of the interest of the interest of the interest of the interest of the interest of the the place of operation and the debt which is due to the interest paid shall be directly related to such a fixed operating facility. In this case, the provisions of Article 7 shall apply.

4. interest shall be deemed to be derived from a Contracting Government when they are paid by a person resident in this Contracting Government. If the person who pays interest rates, whether he is the resident of a Contracting Government or not, has a fixed operation location in a Contracting Government for which the debt ratio, the interest rate paid, was the diocese, and such interest whereas, however, such interest shall be deemed to have been taken from the Contracting Government where the fixed operating location is situated.

5. If a special connection between the person who pays and the rightful owner, or between them and a third person, has caused interest to interest rates in relation to the debt relief for which they are paid exceeds the amount which would have been The provisions of this Article shall apply only to the latter amount, as agreed between the paying and the rightful owner, as provided for in this Article. In this case, the excess amount may be taxed in accordance with the legislation of each Contracting Government, taking into account the other provisions of this Agreement.

Article 12

ROYALTIES

1. Royalties arising from a Contracting Government and paid to a person resident in the other Contracting Government may be subject to tax in this other state.

Paragraph 2 of the Royalties referred to in paragraph 3 (a) may also be taxed in the Contracting Government from which they originate and in accordance with the law of this State, but if the rightful owner of the royalty amount is indigenous to the other Contracting Government, the tax thus impeached shall not exceed 10%. of the gross amount of the royalty amount.

The competent authorities of the Contracting Parties shall lay down by mutual agreement the detailed rules for the implementation of this limitation.

3. The term ' royalties ` means in this Article payments of any kind received as payment for the use or the right to use :

a) any patent, trade mark, pattern or model, drawing, secret formula or method of manufacture, computer software, or any industrial, commercial or scientific equipment, or information on industrial, commercial or scientific knowledge ; experience ;

b) any copyright to a literary, artistic or scientific work, including cinema and film or tape intended for broadcasting on television or radio.

However, the term 'royalties' does not include income covered by Article 8.

4. The provisions of paragraph 1 and 2 shall not apply where the legal owner of a Contracting Government belongs to a Contracting Government, operates in the other Contracting Government, from which the royalty amount originates, through one there ; in the case of permanent operating conditions, and the right which is based on the payment of royalties shall be directly related to such a fixed operating facility. In this case, the provisions of Article 7 shall apply.

5. Royalties shall be deemed to originate from a Contracting Government when they are paid by a person resident in this Contracting Government. If the person who pays the royalty amount, whether he is a resident of a Contracting Government or not, has a fixed operation location in a Contracting Government in connection with which the obligation to pay the royalty amount was set, and such whereas, however, royalties are the responsibility of such a holding shall be deemed to be derived from the Contracting Government in which the fixed operating location is situated.

6. If a specific link between the person paying and the rightful owner, or between them and a third person, has caused the amount of the royalty to be seen in relation to the application, rights or information for which it is paid exceeds the amount of the payment, or amounts which would have been agreed between the paying and the rightful owner, provided that such a relationship had not been available, the provisions of this Article shall apply only to the latter amount. In this case, the excess amount may be taxed in accordance with the legislation of each Contracting Government, taking into account the other provisions of this Agreement.

ARTICLE 13

CAPITAL GAINS

1. Profit, as a person belonging to a Contracting Government, the transferee of the immovable property referred to in Article 6, which is situated in the other Contracting Government, may be subject to the taxable state of this other State.

2. Proceeding by Disposal of the Pipe Property, which forms part of the business asset in a fixed operating facility in a Contracting Government, in the other Contracting Government, including the profit of the disposal of such a fixed operating location, (separately or jointly with the entire undertaking) may be taxed in this other state.

3. Proceeding to the disposal of ships or aircraft used in international traffic or by a piping of a piping of a piping of such ships or aircraft may only be taxed in the Contracting Government where the real management of the enterprise has its seat.

4. Proceeding to the disposal of containers (including trailers, barges and similar equipment for the carriage of containers) used for the carriage of goods in international traffic may only be taxed in the Contracting Government where the actual operation of the undertaking is carried out ; Leadership has its seat.

5. Profit, as a person belonging to a Contracting Government, the transferee of shares or other rights whose value for more than 50 pct.s directly or indirectly comes from immovable property situated in the other ; Contracting Governments may be taxed in this other state.

6. Proceeding to the disposal of all assets other than those referred to in paragraph 1, 2, 3, 4 and 5 shall be subject to tax only in the Contracting Party in which the disposable person is situated.

7. If the undertakings from different countries have agreed to drive ships or aircraft in international traffic through a business consortium, the provisions of this Article shall apply only to the part of the profit corresponding to that part of the consortium owned by an undertaking with a seat for the real management of a Contracting Government.

ARTICLE 14

INCOME FROM PERSONAL WORK IN EMPLOYMENT RELATIONS

Subject to the provisions of Articles 15, 17 and 18, other charges may be paid, salary and other similar charges acquired by a person resident in a Contracting Government, for personal work only subject to taxation in this State unless the work is carried out ; has been carried out in the other Contracting Government. If the work has been carried out there, it may be taxed in this other state.

Notwithstanding the provisions of paragraph 1, remuneration acquired by a person resident in a Contracting Government for personal work carried out in the other Contracting Government shall be taxed only in the first state if all of the following : conditions have been met :

a) the consignee is personally working in the other State of one or more periods which together do not exceed 183 days in a 12-month period beginning or ends in that fiscal year, and

b) the remuneration is paid for by or for an employer not resident in the other State ; and

c) the remuneration is not borne by a fixed operating facility in the other Member State.

3. In the calculation of periods, as mentioned in paragraph 2 (a), the following days shall be taken into account :

a) all days of physical presence, including arrival and departure days, and

b) days spent outside of the State in which personal work is carried out, such as Saturdays and Sundays, national holidays, holiday days and business trips that are directly related to the recipient's personal work of this State, but which are carried out after the conclusion of the recipient activity on the territory of this State.

4. Slice 2 shall not apply to remuneration acquired by a person resident in a Contracting Government for personal work carried out in the other Contracting Government and where the remuneration is paid by or for an employer who is not, is established in this other State if :

a) the consignee shall perform the duties in the personal work of any person other than the employer, directly or indirectly, guiles or controls the manner in which these tasks are performed ; and

b) the employer shall not be responsible for the provision of the results to be ensured by the performance of the tasks.

Notwithstanding the previous provisions of this Article, remuneration for personal work carried out on board a ship or aircraft used in international traffic shall be subject to taxation in the Contracting Government where the real management of the enterprise has its seat.

6. Notwithstanding the provisions of paragraph 5, income obtained from a firm operating location in Denmark of the Danish, Norwegian and Swedish air consortium Scandinavian Airlines System (SAS) may be obtained for personal work on board a plane in international air ; traffic, taxed in Denmark.

Article 15

CONSTYLIORAR MANAGEMENT

Administrative orars and other similar charges obtained by a person resident in a Contracting Government, in his capacity as a member of the board or any other similar body in a party belonging to the other ; Contracting Governments may be taxed in this other state.

Article 16

ARTISTS AND SPORTSMEN

Notwithstanding the provisions of Articles 7 and 14, income acquired by a person resident in a Contracting Government such as theatre, film, radio or television shows or musician, or as a sportscader, can be obtained ; his personal practised activity as such in the other Contracting Government is subject to taxation in this State.

2. If the income of personal business practised by performers or sportsmen does not belong to the artist or the sportsman himself, but a different person, this income may, notwithstanding the provisions of Articles 7 and 14, are taxed in Contracting Government where the activities of the artist or the sportsmen and sportsmen are exercised.

Article 17

PENSIONS, SOCIAL SERVICES AND SIMILAR PAYMENTS

Without prejudice to the provisions of Article 18, paragraph 2, payments may, as a natural person resident in a Contracting Government, receive after the social security law of the other Contracting Government or after any other ; from the funds provided for by this other State or to a related political subsection or by local authority, shall be subject to taxation in this other state.

2. Without prejudice to the provisions of paragraph 1 of this Article and Article 18, paragraph 2, other, pensions and other similar charges may be obtained from a Contracting Government and paid to a person resident in the other Contracting Party ; State, whether this happens to an earlier service or not, is taxed only in this other Contracting Government. However, pensions and other similar charges may be taxed in the first Contracting Government if the scheme is tax-recognised in this State, which means that :

a) contributions paid by the beneficiary to the pension scheme wholly or partially have been deducted from the taxable income of the consignee in this State, in accordance with the law of this State ; or

b) the full contribution of an employer has not been co-calculated in the recipient ' s taxable income in this State, in accordance with the law of that State.

Article 18

PUBLICITY

3. The provisions of Articles 14, 15, 16 and 17 shall apply to salaries, salaries, pensions and other similar charges paid for the performance of the business operations operated by a Contracting Government or belonging to a Contracting Party ; political subdivision or a local authority thereof.

Article 19

STUDENTS

Amounts received for subteams, study or similar training for a student or apprentice which is or, immediately before he visits, a Contracting Government was resident in the other Contracting Government and residing in it ; in the case of the former state, only in the case of study or training purposes, shall not be taxed in this state, provided that such amounts derive from sources outside that state.

Article 20

OTHER INCOME

1. Income, acquired by a person resident in a Contracting Government which has not been treated in the preceding Articles of this Agreement, irrespective of where they originated, only be taxed in this state.

2. The provisions of paragraph 1 shall not apply to income, with the exception of the income of real estate as defined in Article 6, paragraph 2, if the recipient of such income is provided by the Contracting Government of such an income in the other ; Contracting Governments through a holding fixed operating location, and the right or property of the income of the paid income is directly related to such a fixed operating facility. In this case, the provisions of Article 7 shall apply.

Article 21

REPEAL OF DOUBLE TAXATION

1. In Denmark, double taxation shall be avoided as follows :

a) Where a person resident in Denmark acquires income which, in accordance with the provisions of this Agreement, should be taxed in the Czech Republic, unless the provisions of point (c result in other provisions should be reduced by the person concerned ; income tax with an amount equal to the income tax paid in the Czech Republic.

b) However, this reduction may not exceed that part of the income tax, calculated before the deduction is given, which may be attributed to the income tax in the Czech Republic.

c) Where a person who is resident in Denmark acquires income which, in accordance with the provisions of this agreement, can only be taxed in the Czech Republic, Denmark may include this income in the taxable amount, but must reduce income tax ; with the part of the income tax, which may be attributing to income derived from the Czech Republic.

Secondly, unless the provisions of the legislation of the Czech Republic on the avoidance of double taxation lead to other, double taxation for a person resident in the Czech Republic shall be avoided as follows :

a) The Czech Republic may, when the taxonable persons resident in the Czech Republic, can count on income in the tax base, which, in accordance with the provisions of this Agreement, may also be taxed in Denmark, but must reduce the amount of the tax, income tax with an amount equal to the income tax paid in Denmark. However, this reduction may not exceed that part of the Czech tax, calculated before the deduction may be granted to the income which, in accordance with the provisions of this Agreement, may be taxed in Denmark.

b) If a person resident in the Czech Republic acquires income which, in accordance with the provisions of this Convention, only subject to taxation in Denmark, the Czech Republic may include this income in the taxable amount, but must be reduced, income tax with that part of the income tax, which can be attributedto income derived from Denmark.

Article 22

NON-DISCRIMINATION

1. Member State nationals of a Contracting Government may not be subject to any tax or related claims in the other Contracting Government which are different or more cumbersome other than the taxation and related requirements of nationals of this other ; state under the same conditions, in particular with regard to the seat of the tax base, shall be or may be subject to notification. Notwithstanding the provisions of Article 1, this provision shall also apply to persons not being resident in one or both of the Contracting Parties.

2. Stateless persons belonging to a Contracting Government may not be subject to any tax or related requirements in any of the Contracting Governments which are different or more cumbersome than the taxation and related requirements, as nationals of the State in question in the same relationship, in particular with regard to the seat of the tax base, shall be or may be subject to the subject of a contract.

3. The taxation of a fixed farm operating in a Contracting Government of the other Contracting Government may not be less advantageous in this state other than the taxation of undertakings in this other state that operates on the same establishment. This provision should not be interpreted as binding a Contracting Government to allow persons belonging to the other Contracting Government, the personal tax benefits, relaxes and reductions, as the result of : a conjugal position or a grievout duty to the families of people who are indigenous to their own territory.

4. Without prejudice to the provisions of Article 9, paragraph 1, Article 11, paragraph 5 or Article 12, paragraph 6, applicable, interest, royalties and other payments made by an undertaking in a Contracting Government to a person resident in a Contracting Party to a person resident ; in the other Contracting Government, the taxable income of such a undertaking shall be deduced under the same conditions as if they had been paid to a person resident in the former state.

5. Undertaking in a Contracting Government whose capital is owned or controlled directly or indirectly, by one or more persons belonging to the other Contracting Government, may not be subject to any of the former state ; taxation and related requirements, which are different or more cumbersome than the taxation and related requirements laid down by other similar undertakings in the former or may be subject to the requirements of such undertakings.

Article 6, notwithstanding the provisions of Article 2, the provisions of this Article shall apply to taxes of any kind and description.

Article 23

PROCEDURE FOR THE CONCLUSION OF RECIPROCAL AGREEMENTS

1. If a person considers that the measures taken by one or both of the Contracting Governments of him may or may not comply with the provisions of this Agreement, he may, irrespective of the legal means, may or may not, in any case, be subject to the provisions of this Agreement. they may be required by the competent authority of the Contracting Government in the internal legislation of these States, where he is a resident or, where his case is subject to Article 22, paragraph 1, of the competent authority, where : He's a citizen. The matter must be brought before three years from the date on which the first notification has been given to the measure resulting from a tax that is not in accordance with the provisions of this Agreement.

2. The competent authority must, where the notice appears to be justified, and if it is not itself able to reach a reasonable solution, the matter shall seek to resolve the matter by mutual agreement with the competent authority of the other Contracting Government for the purposes of : to avoid a tax that is not in conformity with this Agreement. Any contract concluded shall be carried out without regard to the time limits laid down in the internal legislation of the Contracting Parties.

3. The competent authorities of the Contracting Parties shall seek mutual agreement to resolve any difficulties or doubts which may arise in the interpretation or application of this Agreement. They can also negotiate the avoidance of double taxation in cases not covered by the agreement.

4. The competent authorities of the Contracting Parties may enter directly to each other, including through a joint committee composed of them themselves or their representatives, with a view to the conclusion of an agreement in accordance with the provisions of the Agreement ; previous paragraphs.

ARTICLE 24

EXCHANGE OF INFORMATION

1. The competent authorities of the Contracting Parties shall exchange such information, which may be foreseen in order to implement the provisions of this Agreement or to the administration or enforcement of internal legislation relating to : taxes of any kind and name imposed on behalf of the Contracting Governments or their political subdivisions or local authorities, to the extent that such taxation does not conflict with the agreement. The exchange of information shall not be limited by Articles 1 and 2.

2. Any information received by a Contracting Government pursuant to paragraph 1 shall be kept secret in the same manner as the information provided under this State ' s internal legislation and may be communicated only to persons or authorities ; (including courts and administrative authorities) involved in the equation, collection, enforcement, enforcement or decision of complaints concerning the taxes referred to in paragraph 1 or the supervision of the aforementioned above. Such persons or authorities may use the information only for such purposes. You must communicate the information to the public, or to court rulings, to the information. Regardless of the information given in the front, information received by a Contracting Government may be used for other purposes, provided that such information may be used for such other purposes in accordance with the law in both States and, provided that the competent authority may, in accordance with the legislation of the Member State concerned, the State providing the information shall be authorised to do so.

The provisions of paragraph 1 and 2 in no case may be interpreted in such a way as to impose an obligation on a Contracting Government to :

a) to carry out administrative areas which are contrary to the legislation and the management practices of this or other Contracting Government ;

b) to provide information which cannot be obtained under the legislation or the normal management practices of this or the other Contracting Government ;

c) to communicate information which would reveal any business, business, industrial, commercial or professional secrecy or information which would be in breach of the general interest ("order public").

4. If a Contracting Government asks for information in accordance with this Article, the other Contracting Government shall use its measures to obtain information in order to obtain the information requested, even though this other : Member States may not need this information for their own tax purposes. The obligation laid down in the preceding period shall be subject to limitations in paragraph 3, but in no case must such restrictions be interpreted in such a way as to enable the Contracting Government to refuse information simply because it is not : not himself has any tax interest in such information.

In no case, the provisions of paragraph 3 may be interpreted as allowing a Contracting Government to refuse information simply because the information is possessive of a bank, other financial institution, representative or person, which is empowered or as a guaran or because the information relates to the ownership of a person.

ARTICLE 25

MEMBERS OF DIPLOMATIC REPRESENTATIONS AND CONSULAR POSTS

Nothing in this agreement affects the tax benefits which members of diplomatic representations or consular offices enjoy in accordance with the general rules or agreements of the international law.

Article 26

TERRITORIAL EXTENSION

1. This Agreement may, either in its entirety or with the necessary modifications, be extended to any part of the territory of the Kingdom of Denmark, which is specifically excluded from the scope of the agreement and which imposes taxes on the corresponding nature of the Agreement, those covered by the Agreement. Any such extension shall have the effect of that date and shall be subject to such changes and conditions, including conditions relating to termination, which may be laid down and agreed between the Contracting Governments of notes to be exchanged ; diplomatic route or otherwise in accordance with their constitutional rules.

2. Unless the Contracting Governments agree otherwise, the termination of the agreement of one of the Parties pursuant to Article 28 shall also apply in the same manner as specified in that Article, the application of the Agreement to those parts of the territory of the Kingdom of Denmark, to which it has been extended in accordance with this Article.

ARTICLE 27

ENTRY INTO FORCE

1. Contracting Governments shall notify each of the diplomatic channels to the other on the conclusion of the procedures laid down in their internal legislation to enter into force of the Agreement. The Agreement shall enter into force on the date of the last of these notification and its provisions shall have effect :

a) in the case of taxes included at the source, for income paid or rewritten, on or after 1. January of the calendar year following the entry into force of the Agreement.

b) in the case of other income taxes, for income in any fiscal year, starting or after 1. January of the calendar year following the entry into force of the Agreement.

The Agreement between the Czech Republic and the Government of the Czech Republic of Denmark and the Government of Denmark on the avoidance of double taxation in respect of income and property taxes, signed in Prague on 5. May 1982 (integrated with the protocol that was signed in Prague on 11. In September 1992, cease to be in force and have an impact on the relationship between the Czech Republic and the Kingdom of Denmark from the date on which this Agreement is effective.

Article 28

TERMINATION

This agreement must remain in force until it is terminated by a Contracting Government. Each Contracting Party may terminate the Agreement by means of diplomatic means giving notice of termination at least six months prior to the end of any calendar year following a period of five years starting from the date of entry into force of the Agreement. In this case, the Agreement shall cease having an effect :

a) in the case of taxes included at the source, for income paid or rewritten, on or after 1. of the following January of the calendar year following the date on which the notification is given ;

b) in the case of other income taxes, for income in any fiscal year, starting or after 1. of January of the calendar year following where the message is given.

In the case of the undersigned, duly authorised by the Member of the European Parliament, signed by this Agreement.

Done at two copies in Prague, the 25th. August, 2011, in English.

PROTOCOL

In the signature of the Agreement between the Kingdom of Denmark and the Czech Republic to the avoidance of double taxation and the prevention of tax evasion as regards income taxes, both parties have agreed that this protocol should be : form an integral part of the Agreement :

1. In the case of Article 4,

Both states confirm that a legal person established in a Contracting Government in accordance with the law of this State and which is generally exempt from that State shall be considered to be the resident of the State in the application of : This agreement.

2. In the case of Article 12, paragraph 2 :

If the Czech Republic following the signing of this Agreement, a collective agreement with another EU Member State shall sign up to a tax on royalties derived from the Czech Republic to a lower rate, including in the case of tax exemption from the rate arising from this Article, the lower rate or tax exemption will automatically apply for the application of this Article from the date on which the agreement between the Czech Republic and the person concerned will be applied. EU Member State has effect.

In the case of the undersigned, duly authorised by the Member of the European Parliament, signed by this Agreement.

Done at two copies in Prague, the 25th. August, 2011, in English.