Czech Republic
A. Progress in the implementation of the minimum standard
The Czech Republic has 92 tax agreements in force1 as reported in its response to the Peer Review questionnaire. Thirty-five of those agreements2 comply with the minimum standard.
The Czech Republic signed the MLI in 2017 and deposited its instrument of ratification on 13 May 2020. The MLI entered into force for the Czech Republic 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.
The Czech Republic has not listed its agreements with Albania, Bahrain, Barbados, Belarus, Bosnia-Herzegovina, Botswana, Brazil, Estonia, Indonesia, Jordan, Kazakhstan, Malaysia, Mongolia, Montenegro3, Morocco, North Macedonia, Panama, Saudi Arabia, Sri Lanka, Thailand, Tunisia, Ukraine, the United Arab Emirates, the United States 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, Morocco, North Macedonia, Panama, Saudi Arabia, Tunisia, Ukraine, the United Arab Emirates and Viet Nam have listed their agreements with the Czech Republic under the MLI.
The Czech republic 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, Montenegro and Sri Lanka.
The Czech Republic is implementing the minimum standard through the inclusion of the preamble statement and the PPT.4
B. Conclusion
Albania, Bahrain, Barbados, Bosnia-Herzegovina, Estonia, Indonesia, Jordan, Kazakhstan, Malaysia, Morocco, North Macedonia, Panama, Saudi Arabia, Tunisia, Ukraine, the United Arab Emirates and Viet Nam have listed their agreements with the Czech Republic under the MLI, which amount to requests to implement the minimum standard.
The Czech Republic 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, North Macedonia, Panama, Saudi Arabia, Thailand, Tunisia, Ukraine, the United Arab Emirates, the United States and Viet Nam.
The Czech Republic indicated in its response to the Peer Review questionnaire that over the next two years, 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 the Czech Republic. The Czech Republic has indicated that to avoid doubts and misunderstandings in the future, the Czech Republic will list only such jurisdictions with which it bilaterally confirms the changes that the MLI would bring to the treaty. After finishing this procedure, the Czech Republic indicated that it would pursue bilateral renegotiations or negotiations of amending protocols to implement the minimum standard in its remaining agreements.
← 1. The Czech Republic 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. The Czech Republic has indicated that discussions are ongoing to implement the minimum standard in the agreement with Montenegro.
← 3. The Czech Republic has listed the agreement with former Serbia and Montenegro under the MLI only in relation to Serbia.
← 4. For its agreements listed under the MLI, the Czech Republic is implementing the preamble statement (Article 6 of the MLI) and the PPT (Article 7 of the MLI).