The treaty regulates mutual relations in the field of personal income tax and corporate income tax in the Czech Republic and in the area of personal income tax and corporate income tax in Kosovo.

Key points of the treaty:

• A permanent establishment (PE) includes the concept of a so-called service PE (if the relevant activities continue for a period or periods exceeding six months in aggregate in any twelve-month period).
• Dividends may also be taxed in the source state – the tax thus imposed will not exceed:
  • 5 % of the dividend gross amount, if the beneficial owner is a company that directly holds at least 25 % of the capital of the company paying the dividend.
  • 15 % of the dividend gross amount in all other cases.
• Interest is taxable only in the state of residence.
• Industrial royalties are also taxable in the source state – the tax so imposed will not exceed 10% of the gross royalty amount.
• Gains from the alienation of property in the case of shares do not contain a real estate clause – they are only taxed in the resident state.

The provisions of this Agreement will be implemented as follows:

a) in the case of taxes withheld from the taxpayer’s income, on income paid or credited on or after 1 January 2024;

b) in the case of other income taxes, on income for each tax year beginning on or after 1 January 2024.