К КОНВЕНЦИИ МЕЖДУ ПРАВИТЕЛЬСТВОМ РОССИЙСКОЙ ФЕДЕРАЦИИ И ПРАВИТЕЛЬСТВОМ ЧЕШСКОЙ РЕСПУБЛИКИ ОБ ИЗБЕЖАНИИ ДВОЙНОГО НАЛОГООБЛОЖЕНИЯ И ПРЕДОТВРАЩЕНИИ УКЛОНЕНИЯ ОТ НАЛОГООБЛОЖЕНИЯ В ОТНОШЕНИИ НАЛОГОВ НА ДОХОДЫ И КАПИТАЛ. Протокол. Правительство РФ. 27.04.07

Article III

     1.  The  first  sentence  of  paragraph  2  of  Article 10 of the
Convention shall be modified as follows:
     "2.  However, such dividends may also be taxed in the Contracting
State  of  which  the  company  paying the dividends is a resident and
according  to  the  laws of that State, but if the beneficial owner of
the dividends is a resident of the other Contracting State, the tax so
charged  shall  not  exceed  10  per  cent  of the gross amount of the
dividends."
     2.  Paragraph 3 of Article 10 of the Convention shall be modified
as follows:
     "3.  The  term  "dividends"  as used in this Article means income
from  shares  or other rights, not being debt-claims, participating in
profits,  as  well  as  other  income  which  is subjected to the same
taxation  treatment  as income from shares by the taxation laws of the
State of which the company making the payment is a resident."