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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 on behalf of each Contracting State or of its political subdivisions or local authorities, 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 the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.

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

  • (a) In Czechoslovakia :
    • (a) the taxes on profits;
    • (b) the wages tax;
    • (c) the tax on income from literary and artistic activities;
    • (d) the agricultural tax;
    • (e) the tax on population income;
    • (f) and the house tax
    • (Hereinafter referred to as "Czechoslovak tax");
  • (b) in Luxembourg :
    • (a) the income tax on individuals;
    • (b) the corporation tax;
    • (c) the taxon fees of directors of companies;
    • (d) the capital tax;
    • (e) and the communal trade tax
    • (hereinafter referred to as "Luxembourg tax").

(4) This Convention shall also apply to any identical or substantially similar taxes which are imposed after the date of signature of this Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify to each other any significant changes which have been made in their respective taxation laws.