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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) The present Convention shall apply to taxes on the income and capital imposed in each of the two States, irrespective of the manner in which they are levied.

(2) There shall be deemed as taxes on the income and capital, the taxes imposed on the total income, on the total capital, or on the elements of income or capital including the taxes on the gains arising from the alienation of movable or immovable property, the taxes on the total amount of salaries paid by the enterprises as well as the taxes on capital appreciations.

(3) The present taxes that especially apply to the present Convention are:

  • (a) With respect to Czechoslovakia:
    • (i) withholding tax on the profits;
    • (ii) the tax on profits;
    • (iii) the tax on salaries;
    • (iv) the tax on income arising from creative literary and artistic activities;
    • (v) the agricultural tax;
    • (vi) the personal income tax;
    • (vii) the tax on constructed buildings,
  • (b) With respect to Tunisia:
    • (i) the company tax;
    • (ii) the tax on industrial and commercial profits;
    • (iii) the tax on non-commercial professions;
    • (iv) the tax on salaries and wages;
    • (v) the agricultural tax;
    • (vi) the tax on capital gains from real estate;
    • (vii) the tax on income from securities;
    • (viii) the tax on income from debt-claims, deposits, securities and current accounts (I.R.C.);
    • (ix) the special contribution towards solidarity;
    • (x) the personal contribution of the State.

(4) The Convention shall apply to taxes of identical or similar nature imposed by one of the Contracting States 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 communicate to each other at the end of every year the substantial changes brought about to their respective tax laws.