background image
Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

PROTOCOL

At the moment of signing of the Agreement between the Czech Republic and the United Arab Emirates for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, the undersigned have agreed upon the following provisions which shall form an integral part of this Agreement:

(1) Nothing in this Agreement shall affect the right of the Government of the United Arab Emirates, its political subdivisions, local authorities or local governments to apply its own laws related to the taxation of income derived from the petroleum and natural resources. Such activities will be taxed according to the law of the United Arab Emirates.

(2) With respect to Article 8, if an enterprise of the Czech Republic is charged to any tax in any State of which Gulf Air is the national carrier (State of Bahrain, State of Qatar, Sultanate of Oman) the Contracting States shall open negotiations without delay with the view of adjusting the exemption provided by this Agreement.

(3) If under any Convention or Agreement or protocol to a Convention or Agreement-signed after the signature of this Agreement-between the Czech Republic and any member State of the Co-operation Council of the Gulf Arab Countries (United Arab Emirates, Kuwait, Kingdom of Saudi Arabia, Bahrain, Qatar and Sultanate of Oman) the Czech Republic accords, as regards the provisions of this Agreement, a treatment more favourable than that accorded to residents of the United Arab Emirates under this Agreement, then as from the date on which the relevant Czech Convention or Agreement or protocol to it enters into effect the same favourable treatment shall automatically apply to residents of the United Arab Emirates under this Agreement.

IN WITNESS WHEREOF, the undersigned, duly authorized thereto have signed this protocol.

DONE at Washington on the thirtieth day of September 1996, corresponding to the seventeenth day of Jumada I 1417 H, in duplicate in the Czech, Arabic and English languages, all texts being equally authentic. In the case there is any divergence of interpretation of the provisions of this Protocol the English text shall prevail.

FOR THE CZECH REPUBLIC:

IVAN KOCARNIK

DEPUTY PREMIER, THE MINISTER OF FINANCE

FOR THE UNITED ARAB EMIRATES:

AHMED HUMAID ALTAYER

MINISTER OF STATE FOR FINANCE AND INDUSTRY