Czechia
A. Progress in the implementation of the minimum standard
Czechia has 95 tax agreements in force1 as reported in its response to the Peer Review questionnaire. Forty-eight of those agreements2 comply with the minimum standard.
Czechia signed the MLI in 2017 and deposited its instrument of ratification on 13 May 2020. The MLI entered into force for Czechia on 1 September 2020. The agreements modified by the MLI come into compliance with the minimum standard once the provisions of the MLI take effect.
Czechia has not listed its non-compliant agreements with Albania, Bahrain, Barbados, Belarus, Bosnia-Herzegovina, Botswana, Brazil, Estonia, Indonesia, Jordan, Kazakhstan, Malaysia, Mongolia, Montenegro3, Morocco, North Macedonia, Panama, Saudi Arabia, Thailand, Tunisia, Ukraine, the United States, Uzbekistan and Viet Nam. These agreements will therefore not, at this stage, be modified by the MLI. Albania, Bahrain, Barbados, Bosnia-Herzegovina, Estonia, Indonesia, Jordan, Kazakhstan, Malaysia, Mongolia, Morocco, North Macedonia, Panama, Saudi Arabia, Thailand, Tunisia, Ukraine and Viet Nam have listed their agreements with Czechia under the MLI.
Czechia has signed a bilateral complying instrument in respect of its agreements with Sri Lanka and the United Arab Emirates.
Czechia indicated in its response to the Peer Review questionnaire that steps have been taken (other than under the MLI) to implement the minimum standard in its agreements with Brazil, Montenegro4 and North Macedonia.
Czechia is implementing the minimum standard through the inclusion of the preamble statement and the PPT.5
B. Conclusion
Albania, Bahrain, Barbados, Bosnia-Herzegovina, Estonia, Indonesia, Jordan, Kazakhstan, Malaysia, Mongolia, Morocco, North Macedonia, Panama, Saudi Arabia, Thailand, Tunisia, Ukraine and Viet Nam have listed their agreements with Czechia under the MLI, which amount to requests to implement the minimum standard.
Czechia has developed a plan for the implementation of the minimum standard in its agreements with Albania, Bahrain, Barbados, Belarus, Bosnia-Herzegovina, Botswana, Estonia, Indonesia, Jordan, Kazakhstan, Malaysia, Mongolia, Morocco, Panama, Saudi Arabia, Thailand, Tunisia, Ukraine, the United States, Uzbekistan and Viet Nam.
Czechia indicated in its response to the Peer Review questionnaire that this year, it intends to expand its list of agreements to be covered under the MLI to include the agreements concluded with jurisdictions that have signed the MLI and have listed their agreements with Czechia. Czechia has indicated that to avoid doubts and misunderstandings in the future, Czechia will list only the agreements with such jurisdictions with which it bilaterally confirms the changes that the MLI would bring to the treaty. After finishing this procedure, Czechia indicated that it would pursue bilateral renegotiations or negotiations of amending protocols to implement the minimum standard in its remaining agreements.
← 1. Czechia has 95 agreements in force. These 95 agreements relate to 96 jurisdictions, because Czechia continues to apply the agreement with former Serbia and Montenegro to both Serbia and Montenegro.
← 2. One of these agreements, the agreement with former Serbia and Montenegro, complies with the minimum standard only in relation to Serbia. Czechia has indicated that domestic procedures are ongoing in preparation for signature of a new agreement that has been negotiated with Montenegro.
← 3. Czechia has listed the agreement with former Serbia and Montenegro under the MLI only in relation to Serbia.
← 4. Czechia indicated in its response to the Peer Review questionnaire that a new agreement with Montenegro has been negotiated.
← 5. For its agreements listed under the MLI, Czechia is implementing the preamble statement (Article 6 of the MLI) and the PPT (Article 7 of the MLI).