Australian Tax Treaties
Czech Agreement
AGREEMENT BETWEEN AUSTRALIA AND THE CZECH REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME
ARTICLE 22
Source of Income
1.
Income, profits or gains derived by a resident of the Czech Republic which, under any one or more of Articles 6 to 8 and 10 to 19, may be taxed in Australia shall for the purposes of the law of Australia relating to Australian tax be deemed to be income from sources in Australia.
2.
Income, profits or gains derived by a resident of Australia which, under any one or more of Articles 6 to 8 and 10 to 19, may be taxed in the Czech Republic shall for the purposes of paragraph 1 of Article 23 and of the law of Australia relating to Australian tax be deemed to be income from sources in the Czech Republic.
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) has modified the application of this tax treaty. A synthesised text of the MLI and this tax treaty is available to facilitate the understanding of how the MLI modifies this tax treaty.
Income, profits or gains derived by a resident of the Czech Republic which, under any one or more of Articles 6 to 8 and 10 to 19, may be taxed in Australia shall for the purposes of the law of Australia relating to Australian tax be deemed to be income from sources in Australia.
2.
Income, profits or gains derived by a resident of Australia which, under any one or more of Articles 6 to 8 and 10 to 19, may be taxed in the Czech Republic shall for the purposes of paragraph 1 of Article 23 and of the law of Australia relating to Australian tax be deemed to be income from sources in the Czech Republic.
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