Double Tax Treaties

[i]) The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (hereinafter "MLI"), published in the Coll. of Laws under no. 339/2018 in the form of Communication of the Ministry of Foreign and European Affairs of the Slovak Republic, modifies double tax treaty concluded between the Slovak Republic and relevant state. It is effective as of 01 January 2019 for the Slovak Republic. For more information about the MLI, please visit the following website: https://www.finance.gov.sk/sk/dane-cla-uctovnictvo/priame-dane/dane-z-prijmu/zmluvy-zamedzeni-dvojiteho-zdanenia/multilateralny-nastroj/multilateralny-nastroj-2.html

[ii]) According to the Notification No. 15851/2001-75 published in the Financial Bulletin No. 17/2001 on the application of the Agreement between the Government of the Czechoslovak Socialist Republic and the Government of the People's Republic of China on the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income No. 41/1998 Coll., the Agreement shall not apply to the territory of Hong Kong, Macao and Taiwan; the Agreement shall apply only to the "mainland China".

[iii]) Notification No. 12057/1997-651 published in the Financial Bulletin No. 7/1997 on the application of the Convention between the Government of the Czech and Slovak Federal Republic and the Government of the United Kingdom of Great Britain and Northern Ireland for the avoidance of double taxation with respect to taxes on income and capital gains No. 89/1992 Coll., clarifies the territorial scope of the Convention as follows : According to the letter a) point 1 of Article 3 of the Convention, the term "United Kingdom" means the Great Britain and Northern Ireland , including any area outside the territorial waters of the United Kingdom . The term Great Britain refers to England, Wales and Scotland. The term United Kingdom does not apply to offshore islands and dependencies (e.g. Isle of Man, the Channel Islands, Gibraltar, the British Virgin Islands etc.). The legislation in the area of finance, economy and trade on these off-shore islands and dependencies differs from the legislation of Great Britain. In these territories, neither legal norms of the European Union transposed into UK law, nor the UK convention for the avoidance of double taxation apply.

Explanatory note: * Protocol to the Agreement