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.
ARTICLE 24
Elimination of Double Taxation
(1) In the case of a resident of Romania, double taxation shall be eliminated as follows:
- Taxes paid by Romanian residents in respect of income or capital taxable in the Czech Republic in accordance with the provisions of this Convention, shall be deducted from the Romanian taxes due according to the Romanian fiscal laws.
- Such deduction shall not, however, exceed that part of the income tax or capital tax, as computed before the deduction is given which is attributable to the income or the capital which may be taxed in the Czech Republic.
(2) In the case of a resident of the Czech Republic, double taxation shall be eliminated as follows:
- The Czech Republic, when imposing taxes on its residents, may include in the tax base upon which such taxes are imposed the items of income which according to the provisions of this Convention may also be taxed in Romania, but shall allow as a deduction from the amount of tax computed on such a base an amount equal to the tax paid in Romania. Such deduction shall not, however, exceed that part of the Czech tax, as computed before the deduction is given, which is appropriate to the income which, in accordance with the provisions of this Convention, may be taxed in Romania.