DoubleTaxationSingapore – Czech Republic tax treaty: residence, 183 days, rates
Agreement between the Government of the Republic of Singapore and the Government of the Czech Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (signed at Singapore on 21 November 1997), with Protocol, as amended by the Protocol of 26 June 2013 and modified by the MLI
- Signed: 21/11/1997
- In force since: 21/08/1998
- Official text
If both countries treat you as resident
- A dual-resident individual is deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available in both States, of the State with which his personal and economic relations are closer (centre of vital interests). Art. 4(2)(a) of the Singapore–Czech Republic Agreement
- If the State of the centre of vital interests cannot be determined, or if he has no permanent home available in either State, he is deemed to be a resident only of the State in which he has an habitual abode. Art. 4(2)(b) of the Singapore–Czech Republic Agreement
- If he has an habitual abode in both States or in neither, he is deemed to be a resident only of the State of which he is a national (c); 'if he is not a national of either State', the competent authorities settle the question by mutual agreement (d). The text does not deal expressly with a national of both States. Art. 4(2)(c), (d) of the Singapore–Czech Republic Agreement
- A person may present a case of taxation not in accordance with the Agreement within three years from the first notification; the competent authorities endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Agreement. Art. 24(1), (3) of the Singapore–Czech Republic Agreement
Income: who taxes it
| Income | Treaty rule | Article |
|---|---|---|
| Salary (employment) | The country where the work is done may tax it. Exempt if all apply: no more than 183 days in any 12-month period; the employer is not resident there; the pay is not borne by its permanent establishment there. | Art. 15(2) |
| Self-employment, business, services | Country of residence; the other country taxes profits of a permanent establishment (fixed base) there, or if your stay there reaches 183 days in any 12-month period. | Art. 7, Art. 14 |
| Pension | Only the country of residence. | Art. 18 |
| Government service | Usually only the paying country; exception: service in the other country by its national. | Art. 19(1)-(2) |
| Government service pension | Usually only the paying country; exception: service in the other country by its national. | Art. 19(1)-(2) |
| Rent from real estate | The country where the property is located may tax; the country of residence relieves double taxation. | Art. 6(1) |
| Dividends | Source country: at most 5%; the country of residence relieves double taxation. | Art. 10(2) |
| Interest (deposits, bonds, loans) | Only the country of residence. | Art. 11(1) |
| Royalties (copyright, licences) | Source country: at most 10%; the country of residence relieves double taxation. Other rates or exemptions apply in some cases (see the article). | Art. 12(2)(b) |
| Sale of property or shares | Real estate: the country where it is located may tax. Other property, including shares: only the country of residence. | Art. 13 |
| Other income | The source country may tax; the country of residence relieves double taxation. | Art. 21 |
How double taxation is relieved
- Czech Republic: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 22(2)(a)
- Singapore: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 22(1)
Data checked: 10/11/2026. A short summary for individuals; the full conditions, exceptions and protocols are in the treaty text. General information, not legal advice.