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 VIII

     Article 24 of the Convention shall be modified as follows:

                             "Article 24
                          Non-discrimination

     1. Nationals of a Contracting State shall not be subjected in the
other  Contracting  State to any taxation or any requirement connected
therewith,  which  is  other  or more burdensome than the taxation and
connected  requirements  to which nationals of that other State in the
same  circumstances,  in  particular with respect to residence, are or
may be subjected. This provision shall, notwithstanding the provisions
of  Article  1,  also apply to persons who are not residents of one or
both of the Contracting States.
     2.  The taxation on a permanent establishment which an enterprise
of  a  Contracting State has in the other Contracting State or a fixed
base  available  to  a  resident  of  a Contracting State in the other
Contracting  State  shall  not be less favourably levied in that other
State  than  the  taxation  levied on enterprises or residents of that
other State carrying on the same activities.
     3.  Nothing  in  this  Article  shall  be construed as obliging a
Contracting State to grant to residents of the other Contracting State
any  personal allowances, reliefs and reductions for taxation purposes
on  account of civil status or family responsibilities which it grants
to its own residents.
     4.  Except  where  the  provisions  of  Article 9, paragraph 5 of
Article  11,  or paragraph 6 of Article 12, apply, interest, royalties
and  other  disbursements paid by an enterprise of a Contracting State
to a resident of the other Contracting State shall, for the purpose of
determining  the  taxable  profits  of  such enterprise, be deductible
under  the  same  conditions as if they had been paid to a resident of
the  first-mentioned State. Similarly, any debts of an enterprise of a
Contracting  State to a resident of the other Contracting State shall,
for the purpose of determining the taxable capital of such enterprise,
be deductible under the same conditions as if they had been contracted
to a resident of the first-mentioned State.
     5.  Enterprises  of  a Contracting State, the capital of which is
wholly  or  partly owned or controlled, directly or indirectly, by one
or  more  residents  of  the  other  Contracting  State,  shall not be
subjected  in  the  first-mentioned  State  to  any  taxation  or  any
requirement connected therewith which is other or more burdensome than
the  taxation  and  connected  requirements  to  which  other  similar
enterprises of the first-mentioned State are or may be subjected.
     6.  The  provisions  of  this  Article shall, notwithstanding the
provisions   of   Article   2,  apply  to  taxes  of  every  kind  and
description."