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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 and on capital imposed on behalf of a Contracting State or of its political subdivisions, local authorities or by its administrative territorial units, irrespective of the manner in which they are levied.

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

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

  • (a) in the Czech Republic:
    • (i) the tax on income of individuals (dan z prijmu fyzickych osob);
    • (ii) the tax on income of legal persons (dan z prijmu pravnickych osob);
    • (iii) the tax on immovable property (dan z nemovitosti);
  • (hereinafter referred to as "Czech tax");
  • (b) in Romania:
    • (i) the tax on income derived by individuals (impozitul pe veniturile realizate de persoanele fizice);
    • (ii) the tax on profits of bodies and legal persons (impozitul pe profiturile realizate de persoanele juridice);
    • (iii) the tax on salaries, wages and other similar remunerations (impozitul pe salarii si alte remuneratii similare);
    • (iv) the tax on dividends (impozitul pe dividende);
    • (v) the tax on income realised from agricultural activities (impozitul pe veniturile realizate din activitati agricole);
  • (hereinafter referred to as "Romanian tax").

(4) This 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 significant changes which have been made in their respective taxation laws within a reasonable period of time after such changes.