The Czech Republic has published Financial Bulletin No. 12/2021 on the impact of the BEPS MLI on the 2014 income tax treaty with Pakistan. The notice includes the amendments made by the MLI to the treaty and their effective date.

The MLI applies for the 2014 Czech Republic-Pakistan tax treaty:

• In the Czech Republic, with respect to taxes withheld at source from amounts paid or credited to non-residents, where the event giving rise to such taxes occurred on or after 1 January 2022;
• In Pakistan, with respect to taxes withheld at source from amounts paid or credited to non-residents, where the event giving rise to such taxes occurred on or after 1 April 2021; and
• In both Contracting States, with respect to all other taxes, for taxes imposed in respect of tax periods beginning on or after 1 October 2021.

Notwithstanding the above, Article 16 of the MLI (Mutual Agreement Procedure) has effect for a case presented to the competent authority of a Contracting State on or after 1 April 2021, except for cases that were not eligible to be presented as of that date under the treaty prior to its modification by the MLI, without regard to the taxable period to which the case relates.