THE CONVENTION BETWEEN THE REPUBLIC OF TAJIKISTAN AND THE CZECH REPUBLIC

of November 7, 2006

About avoidance of double taxation concerning taxes on the income and the capital

The Republic of Tajikistan and the Czech Republic being guided by the aspiration to develop and strengthen economic, scientific, technical and cultural cooperation between both States decided to sign this Convention "About Avoidance of Double Taxation concerning Taxes on the Income and the Capital" and agreed as follows:

Article 1 of Person to which the Convention is applied

This Convention is applied to persons who are residents of one or both Contracting States.

Article 2 Taxes to which the Convention extends

1. This Convention is applied to taxes on the income and the capital levied on behalf of one of Contracting States or its political divisions or regional authorities irrespective of method of their collection.

2. All taxes levied from total of income on the total amount of the capital, or from separate elements of the income or the capital, including taxes on the income from alienation of personal and real estate, taxes levied from the salary fund or the salary paid by the companies and also the taxes levied from the income from capital gain are considered as taxes on the income (profit) and the capital.

3. In particular, treat the taxes operating now to which operation of this Convention extends:

a) in the Republic of Tajikistan:

- tax on the income (profit) of legal entities,

- the income tax from physical persons;

- property tax of legal entities and physical persons; (further the referred to as "Tajik taxes");

b) in the Czech Republic:

- income tax of physical persons;

- income tax of legal entities;

- non-personal taxes,

(further the referred to as "Czech taxes")

4. This Convention is applied also to any to similar or in essence to similar taxes which will be levied after signing of this Convention in amendment or instead of the existing taxes. Competent authorities of Contracting States will notify each other on any essential changes which will be made to their tax legislations.

Article 3 General determinations

1. For the purpose of this Convention if other does not follow from context:

a) the terms "Contracting State" and "other Contracting State" mean, depending on context, the Czech Republic or Tajikistan.

b) the term "Tajikistan" is meant by Republic of Tajikistan, when using in geographical sense the term Tajikistan includes its territory, determined according to its international legislation

c) the term "Czech Republic" means the territory of the Czech Republic where, according to the legislation of the Czech Republic and according to the international legislation the sovereign rights of the Czech Republic are observed:

d) the term "person" includes physical person, the company and any other consolidation;

e) the term "company" means any corporate consolidation or any other organization which for the purposes of the taxation is considered as corporate consolidation;

f) the term "company" extends to any kind of activities;

q) the term "company of the Contracting State" and "company of other Contracting State" mean respectively the company managed by resident of one Contracting State and the company managed by resident of other Contracting State;

h) the term "international delivery" means any transportation sea, air, automobile and railway the vehicles operated by the company of the Contracting State in which the management place is located, except as specified, when sea, air, automobile and the rail vehicle is operated only between Items in other Contracting State;

i) the term "activities" also includes provision of professional services and other types of activity of individual nature;

j) the term "national person" means;

- any physical person having nationality of the Contracting State;

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