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 23
Elimination of Double Taxation
(1) In the case 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 or capital which according to the provisions of this Convention may also be taxed in the Russian Federation, but shall allow as a deduction from the amount of tax computed on such a base an amount equal to the tax paid in the Russian Federation. 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 or capital which, in accordance with the provisions of this Convention, may be taxed in the Russian Federation. Where in accordance with any provision of the Convention income derived or capital owned by a resident of the Czech Republic is exempt here from tax, the Czech Republic may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.
(2) In the case of the Russian Federation, double taxation shall be eliminated as follows:
- If a resident of the Russian Federation draws income or has capital which in accordance with the provisions of this Convention may be taxed in the Czech Republic the amount of tax on such income or capital to be paid in the Czech Republic shall be deducted from the tax charged on that person in the Russian Federation. Such deduction, however, shall not exceed the amount of tax charged on such income or capital in accordance with the laws and rules of the Russian Federation.