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 IV

     1.  Paragraph 1 of Article 11 of the Convention shall be modified
as follows:
     "1.  Interest  arising  in  a  Contracting State and beneficially
owned  by  a  resident of the other Contracting Slate shall be taxable
only in that other State."
     2. Second sentence shall be added to paragraph 2 of Article 11 of
the Convention that shall read as follows:
     "The  term  "interest" shall not include any item of income which
is  considered  as  a  dividend under the provisions of paragraph 3 of
Article 10."
     3. New paragraph 4 shall be added to Article 11 of the Convention
that shall read as follows:
     "4. Interest shall be deemed to arise in a Contracting State when
the  payer  is  that  State  itself,  a political subdivision, a local
authority  or  a  resident  of  that State. Where, however, the person
paying  the  interest, whether he is a resident of a Contracting State
or  not,  has  in  a  Contracting State a permanent establishment or a
fixed  base  in  connection  with  which the indebtedness on which the
interest  is  paid  was  incurred,  and such interest is borne by such
permanent  establishment  or  fixed  base, then such interest shall be
deemed  to  arise  in  the  Contracting  State  in which the permanent
establishment or fixed base is situated."
     4. The existing paragraph 4 of Article 11 of the Convention shall
be renumbered as paragraph 5.