International tax relations11/09/09 / cata_tax-news
The Ministry of Foreign Affairs’ Communication on conclusion of the Protocol to the Agreement between the governments of the Czech Republic and Russian Federation on the Abolition of Double Taxation and Prevention of Tax Evasion in the Field of Income Taxes and Property Taxes was published in the Collection of Treaties on 9 July 2009, Chapter No. 24/2009.
The new protocol amending the current agreement on the abolition of double taxation came into effect on 17 April 2009. The current agreement is amended by a new provision regulating the creation of a permanent establishment for services following six months of provision of services. Other changes include, for example, the taxation of income from the disposal of shares or other rights in a company the registered capital of which constitutes 50% or more real property. Such gains shall be subject to taxation in the country where the real property is located. These changes in the agreement on the abolition of double taxation shall be applied as of the taxation period beginning on 1 January 2010.