Double taxation treaty with Belarus partially suspended
The Ministry of Finance has announced that the implementation of a part of the Treaty with Belarus shall be suspended in the period from 1 June 2024 to 31 December 2026.
Belarus has informed the Czech Ministry of Foreign Affairs that it will no longer implement Articles 10, 11 and 13 of the Treaty on the Avoidance of Double Taxation between the Czech Republic and Belarus for the period between 1 June 2024 and 31 December 2026. The mentioned articles concern the taxation of dividends, interest, and income from the disposal of property. The Ministry of Foreign Affairs has announced this fact in the Collection of Laws under No. 115/2024 Coll.
Following the Belarusian approach, the Czech Ministry of Finance announced in the Financial Bulletin No. 4/2024 that the Czech Republic shall also not apply Articles 10, 11, and 13 of the Treaty in the period in question.
The ministry further stated that as a result of the suspension of Articles 10, 11, and 13 of the Treaty, the situation where one of the parties would be obliged to exclude double taxation cannot arise. Therefore, Article 23 shall not apply either. Similarly, the dispute settlement procedures under Article 25 will not be applicable.