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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 in one of the Contracting States, 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, taxes on wages or salaries, as well as taxes on capital appreciation.

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

  • (a) In the Federal Republic of Germany:
    • (1) The income tax (Einkommensteuer);
    • (2) The corporation tax (Körperschaftsteuer), including the supplementary corporation tax (Ergänzungsabgabe);
    • (3) The tax on capital (Vermögensteuer);
    • (4) The real property tax (Grundsteuer); and
    • (5) The business tax (Gewerbesteuer);
  • (b) In the Czechoslovak Socialist Republic:
    • (1) The taxes on profits (odvod ze zisku a dan ze zisku);
    • (2) The wages tax (dan ze mzdy);
    • (3) The tax on income from literary and artistic activities (dan z prijmu z literární a umelecké cinnosti);
    • (4) The agricultural tax (dan zemedelská);
    • (5) The tax on population income (dan z prijmu obyvatelstva);
    • (6) The house tax (dan domovní); and
    • (7) The capital tax (odvod z jmení).

(4) The provisions of this Convention concerning the taxation of income or capital shall apply mutatis mutandis to the business tax, levied in the Federal Republic of Germany, which is not computed on the basis of income or property.

(5) The Convention shall apply also to any identical or similar taxes which are subsequently imposed in addition to, or in place of, the existing taxes. At the end of each year, the competent authorities of the Contracting States shall, if necessary, notify each other of changes which have been made in their respective taxation laws.