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Czech Republic Confirms Activation of MFN in Tax Treaty with Colombia

19 May 2023

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Treaty Development

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Czech Republic-Colombia

The Czech Republic has published Financial Bulletin No. 7/2023, which confirms the activation of the MFN clause in the 2012 income tax treaty with Colombia. As a result of Colombia's tax treaty with the United Kingdom, income from the provision of technical assistance, technical services, or consulting services is no longer taxed under Article 12 (Royalties) starting from 1 January 2020. Instead, such income is taxed under Article 7 (Business Profits), meaning that the income is only taxed if attributable to a permanent establishment. For this purpose, paragraph 3(b) of Article 5 (Permanent Establishment) is taken into account, which provides...