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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.

ARTICLE 2

Taxes Covered

(1) This Convention shall apply to taxes on income imposed on behalf of a Contracting State or of its political subdivisions, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income 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;
    • (ii) the tax on income of legal persons;
  • (hereinafter referred to as "Czech tax");
  • (b) in South Africa:
    • (i) the normal tax;
    • (ii) the non-resident shareholders' tax; and
    • (iii) the secondary tax on companies;
  • (hereinafter referred to as "South African 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.