Investor Presentaiton
According to the Czech tax law, a permanent establishment
('PE') means a facility (fixed place of a business) located
in the Czech Republic, where a Czech non-resident entity
carries on its activity in the Czech Republic. A PE should
mean for example an office, workshop, place of sale (sales
area) or a building site ('fixed place PE'). Further, a PE of
a non-resident can also be created in the Czech Republic
provided that the employees or other personnel engaged
by the non-resident are active in provision of services in
the Czech Republic for a period of six months within any
12-month period ('service PE'). Separately, if a person is
acting on behalf of a non-resident on the territory of the
Czech Republic and has and habitually exercises authority
to conclude contracts that are binding for the non-resident,
then a PE of the non-resident is deemed to exist in the
Czech Republic in respect of all activities which that person
undertakes for the non-resident ('agent PE').
Tax liabilities may in certain cases be mitigated or
eliminated by tax treaties, where applicable. In particular, if
an applicable tax treaty is in place, then:
. Income from services are usually taxed only if the
services are deemed to be provided via a permanent
establishment in the Czech Republic.
.
Income from employment is usually taxed only if the
individual is employed by a Czech company or whose
salary is attributed to a Czech permanent establishment
of a foreign company, or if he/she spends more than 183
days in the Czech Republic.
Certain categories of income earned by non-residents,
including dividends, interest, royalties and fees for
services rendered in the Czech Republic are liable to
a withholding tax at a rate of 15 percent. The rate is
increased to 35 percent if the income is paid to residents
of countries that have not signed a double taxation treaty
with the Czech Republic, and when no arrangement is in
place for the exchange of information on tax matters.
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