Czech Rep Tax News
ECJ holds French withholding tax on outbound dividends incompatible with freedom of establishment
ECJ: previous UK ACT regime regarding outbound dividends compatible with EC fundamental freedoms (ACT IV GLO) – details
Protocol to treaty between Czech Republic and Russia initialled
Treaty between Austria and Czech Republic ratified
European Commission requests Belgium, Italy, Luxembourg, Netherlands, Portugal and Spain to terminate discriminatory taxation of outbound dividends
European Commission refers Italy and Luxembourg to ECJ for not implementing Directive amending EC Parent-Subsidiary Directive
European Commission decides that Luxembourg's preferential tax regime for 1929 holding companies constitutes incompatible state aid
European Commission requested Spain to end infringement to the EC Parent-Subsidiary Directive concerning the use of anti-abuse measures
European Commission requests Belgium to terminate discriminatory taxation of inbound dividends
Treaty between Czech Republic and Austria signed
Treaty between Czech Republic and New Zealand– negotiations concluded
Treaty between Czech Republic and China (People's Rep.) initialled
The first-time income and capital tax treaty between the Czech Republic and Korea (Dem. People's Rep.), signed on 2 March 2005, entered into force on 7 December 2005. The treaty generally applies from 1 January 2006.
On 8 December 2005 China (People's Rep.) and the Czech Republic agreed to conclude a new tax treaty as soon as possible. The new treaty would replace the China-Czechoslovakia treaty of 11 June 1987, which currently applies to relations between China and the Czech Republic.
New Decree on application of tax treaties and taxation of Czech-source income of non-residents
Details of the new Czech Republic-Norway income tax treaty, signed on 19 October 2004, have become available. The treaty entered into force on 9 September 2005 and will generally apply from 1 January 2006. From this date, the new treaty will generally replace the Norway-former Czechoslovakia income and capital tax treaty and protocol of 27 June 1979 in respect of relations between Norway and the Czech Republic. The treaty was concluded in the English language. The treaty generally follows the OECD Model Convention and is probably one of the first treaties to contain the text of the Exchange of Information article (Art. 25) in the form included in the 2005 OECD Model update. It should also be noted that the treaty deals with mutual assistance in the collection of taxes between the Czech Republic and Norway (Art. 26).
The new income tax treaty between Norway-Czech Republic, signed on 19 October 2004, entered into force on 31 August 2005. The treaty generally applies from 1 January 2006. From this date, the new treaty generally replaces the Norway-former Czechoslovakia income and capital tax treaty and protocol of 27 June 1979 in relations between Norway and the Czech Republic.
The Czech Republic and Austria initialled a new income tax treaty on 15 July 2005. Once in force, the new treaty will replace the Czech Republic and Austria income and capital tax treaty of 7 March 1978. Further details of the new treaty will be reported subsequently
Landmark decision of Czech Supreme Administrative Court Treatment of interest reclassified under thin capitalization rules; Treaties with the Netherlands and US
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