Informace ke smlouve o zamezeni dvojiho zdaneni s Ruskem

Information on the double taxation treaty with Russia

The General Financial Directorate (GFD) has issued information on the suspension of the application of selected articles of the double taxation treaty with Russia (DTT). Following the previous communication of the Ministry of Finance, the GFD issues a more detailed information explaining in more detail the effects of the suspension of the application of selected articles of the DTT and illustrating them with practical examples - more details HERE.

The information provides the GFD's perspective on, inter alia, the following aspects:

• Despite the suspension of the implementation of certain articles of the DTT, Russia can still be classified as a country whose tax residents’ income is not subject to the special withholding tax rate of 35%.
• From 29 September 2023, double taxation relief under Article 23 of the DTT cannot be applied.
• For the period from 11 August 2023 to 28 September 2023, a Czech taxpayer may choose whether to treat Russia as a state with which the Czech Republic has a treaty for the avoidance of double taxation of all types of income that is applied or, on the contrary, as a state where no such treaty is applied for the purposes of eliminating or mitigating the effects of double taxation.
• The information provides guidance on how to determine when the income was realised and which regime it therefore falls under.

If this is an area of interest to you, please contact the authors of the article or the advisory team you usually work with.

Authors:

Lucie Říhová

Karel Hronek