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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.


Taxes Covered

(1) This Convention shall apply to taxes on income imposed on behalf of a Contracting State or of its political or administrative subdivisions or local authorities, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income all taxes imposed on total income or on elements of income, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.

(3) The existing taxes to which the Convention shall apply are:

  • (a) In the case of Portugal:
    • (i) the personal income tax (Imposto sobre o Rendimento das Pessoas Singulares  IRS);
    • (ii) the corporate income tax (Imposto sobre o Rendimento das Pessoas Colectivas  IRC); and
    • (iii) the local surtax on corporate income tax (Derrama);
  • (hereinafter referred to as "Portuguese tax");
  • (b) In the case of the Czech Republic:
    • (i) the tax on income of individuals (dan z prijmu fyzickych osob); and
    • (ii) the tax on income of legal persons (dan z prijmu pravnickych osob);
  • (hereinafter referred to as "Czech tax").

(4) The Convention shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of the Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any substantial changes which have been made in their respective taxation laws.