Australian Tax Treaties
Slovak Agreement
AGREEMENT BETWEEN AUSTRALIA AND THE SLOVAK REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME
ARTICLE 21
Income Not Expressly Mentioned
1.
Items of income of a resident of a Contracting State which are not expressly mentioned in the foregoing Articles of this Agreement shall be taxable only in that State.
2.
However, any such income derived by a resident of a Contracting State from sources in the other Contracting State may also be taxed in that other State.
3.
The provisions of paragraph 1 shall not apply to income, other than income from " real property " as defined in paragraph 2 of Article 6, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the income is paid is effectively connected with that permanent establishment or fixed base. In either case, the provisions of Article 7 or Article 14, as the case may be, shall apply.
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.
Items of income of a resident of a Contracting State which are not expressly mentioned in the foregoing Articles of this Agreement shall be taxable only in that State.
2.
However, any such income derived by a resident of a Contracting State from sources in the other Contracting State may also be taxed in that other State.
3.
The provisions of paragraph 1 shall not apply to income, other than income from " real property " as defined in paragraph 2 of Article 6, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the income is paid is effectively connected with that permanent establishment or fixed base. In either case, the provisions of Article 7 or Article 14, as the case may be, shall apply.
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