PROTOCOL
At the moment of signing the Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, this day concluded between the Kingdom of the Netherlands and the Czechoslovak Socialist Republic, the undersigned have agreed that the following provisions shall form an integral part of the Convention.
(I) Ad Article 4:
An individual living aboard a ship without any real domicile in either of the States shall be deemed to be a resident of the State in which the ship has its home harbour.
(II) Ad Articles 10, 11 and 12:
Applications for the restitution of tax levied contrary to the provisions of Articles 10, 11 and 12 have to be lodged with the competent authority of the State having levied the tax within a period of three years after the expiration of the calendar year in which the tax has been levied.
(III) Ad Article 25:
It is understood that, in so far as the Netherlands income tax or company tax is concerned, the basis mentioned in Article 25, A, paragraph 1 is the "onzuivere inkomen" or "winst" in terms of the Netherlands Income Tax Law or Company Tax Law, respectively.
*(IV) Ad Article 28 - [DELETED]
DONE at Prague, on 4 March 1974, in two originals, each in the Netherlands, Czech and English languages, the three texts being equally authentic. In case there is any divergence of interpretation between the Netherlands and Czech texts, the English text shall prevail.
IN WITNESS WHEREOF, the undersigned, duly authorised thereto, have signed this Protocol.