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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 by its local authorities or its administrative-territorial units, 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 as well as taxes on capital appreciation.

(3) The existing taxes to which this Convention shall apply are:

  • (a) in the Slovak Republic:
    • (i) the tax on income of individuals;
    • (ii) the tax on income of legal persons;
    • (iii) the tax on immovable property;
  • (hereinafter referred to as "Slovak tax");
  • (b) in Romania:
    • (i) the tax on income derived by individuals;
    • (ii) the tax on the profits of legal persons;
    • (iii) the tax on salaries and other similar remunerations;
    • (iv) the tax on income realised from agricultural activities;
    • (v) the tax on dividends;
  • (hereinafter referred to as "Romanian tax").

(4) This Convention shall apply also 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 referred to in paragraph (2). The competent authorities of the Contracting States shall notify each other of any significant changes which have been made in their respective taxation laws.