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
Provisions to Eliminate Double Taxation
Double Taxation shall be avoided in the following manner:
(1) In Czechoslovakia:
- (a) Where a resident of Czechoslovakia receives income or owns capital which, in accordance to the provisions of the present Convention, is taxable in Tunisia, Czechoslovakia shall exempt such tax on such income or capital, subject to the provisions of paragraphs (2) and (3).
- (b) Where, a resident of Czechoslovakia receives elements of income which, in accordance to the provisions of Articles 10, 11, 12, 16 and 17, are taxable in Tunisia, Czechoslovakia shall allow, a deduction from the tax on the income of such resident an amount equal to the tax paid in Tunisia. This deduction shall however, not exceed the fractions of tax calculated before deduction, attributable to such items of income received from Tunisia.
- (c) Where, in accordance to any provision of the Convention, the income that a resident of Czechoslovakia receives or capital that he owns are exempted from tax in Czechoslovakia, may nevertheless, in order to calculate the amount of tax on the remaining income or capital of this resident, due regard being had to the exempted income or capital.
(2) In Tunisia:
- (a) Where a resident receives income or owns capital which, in accordance to the provisions of the present Convention, is taxable in Czechoslovakia, Tunisia shall allow as a deduction from the tax on the income of that resident an amount equal to the income tax paid in Czechoslovakia.
- (b) Where, in accordance to any provision of the Convention, the income that a resident of Tunisia, receives or capital that he owns are exempted from tax in Tunisia, may nevertheless, in order to calculate the amount of tax on the remaining income or capital of that resident, due regard being had to the exempted income or capital.
(3) The tax that that is levied, for a limited period of time, on an exemption or reduction in one of the Contracting States, by virtue of the national legislation of the aforementioned State, shall be deemed to have been charged and it must be deducted in the other Contracting State from the tax due on such income.