Clarification on Applicability of DTA Agreement with Czechoslovak Socialist Republic to Slovak Republic

NOTIFICATION NO. 25/2015

New Del­hi, the 23^rd March, 2015

Where­as a Agree­ment between the Gov­ern­ment of the Repub­lic of India and the Gov­ern­ment of the Czechoslo­vak Social­ist Repub­lic was signed on the 27th Jan­u­ary, 1986 for the avoid­ance of dou­ble tax­a­tion and the pre­ven­tion of fis­cal eva­sion with respect to tax­es on income and the same was pub­lished in the Gazette of India, Extra­or­di­nary, part II, ‑Sec­tion 3, Sub-sec­tion (i), vide num­ber G.S.R.526 (E), dat­ed the 25th of May, 1987;

And where­as the Slo­vak Repub­lic is one of the inde­pen­dent States that have suc­ceed­ed the Czechoslo­vak Social­ist Republic;

And where­as under the applic­a­ble inter­na­tion­al laws regard­ing appli­ca­tion of treaties in case of suc­ces­sion of States, this Agree­ment con­tin­ues to be applic­a­ble in respect of the Slo­vak Repub­lic, being one of the inde­pen­dent States to have suc­ceed­ed the Czechoslo­vak Social­ist Republic;

Now, there­fore, in exer­cise of the pow­ers con­ferred by sec­tion 119 of the Income-tax Act, 1961 (43 of 1961), the Cen­tral Board of Direct Tax­es here­by clar­i­fies that for the pur­pos­es of sec­tion 90 of the said Act, the Agree­ment signed between the Gov­ern­ment of the Repub­lic of India and the Gov­ern­ment of the Czechoslo­vak Social­ist Repub­lic on the 27^th  Jan­u­ary 1986 for the avoid­ance of dou­ble tax­a­tion and the pre­ven­tion of fis­cal eva­sion with respect to tax­es on income con­tin­ues to be applic­a­ble to the res­i­dents of the Slo­vak Republic.

[F.NO.501/12/1995-FTD‑I]