Convention entre la République du Cameroun et la République…

Convention fiscale bilatérale signée à Yaoundé le 7 février 2023 entre la République du Cameroun et la République tchèque. Elle vise à éviter la double imposition et à prévenir l'évasion fiscale en matière d'impôts sur le revenu. Le texte définit les personnes et impôts couverts, les règles de résidence, l'établissement stable, et répartit les droits d'imposition entre les deux États. Signée en français, tchèque et anglais, avec prévalence du texte anglais en cas de divergence.

REPUBLIQUE DU CAMEROUN - REPUBLIC OF CAMEROON MINISTERE DES RELATIONS EXTERIEURES - MINISTRY OF EXTERNAL RELATIONS

CONVENTION

BETWEEN

THE REPUBLIC OF CAMEROON

AND

THE CZECH REPUBLIC

FOR THE AVOIDANCE OF DOUBLE TAXATION

AND THE PREVENTION OF FISCAL EVASION

WITH RESPECT TO TAXES ON INCOME

THE REPUBLIC OF CAMEROON AND THE CZECH REPUBLIC,

DESIRING to further develop their economic relations and to enhance their co-operation in tax matters by way of concluding a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance,

HAVE agreed as follows:

ARTICLE 1

PERSONS COVERED

This Convention shall apply to persons who are residents of one or both of the Contracting States.

ARTICLE 2

TAXES COVERED

This Convention shall apply to taxes on income imposed on behalf of a Contracting State or of its territorial-administrative subdivisions or local authorities, irrespective of the manner in which they are levied.

There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.

The existing taxes to which the Convention shall apply are in particular:

a) in the case of Cameroon:

(i) the personal income tax; (ii) the company tax; (iii) the minimum tax on companies and individuals; (iv) the special tax on income paid to persons resident out of Cameroon; and (v) the housing loans fund tax and other taxes based on salaries, as well as other withholding taxes and prepayments or surcharges to the said taxes;

(hereinafter referred to as “Cameroonian tax”); and

b) in the case of the Czech Republic:

(i) the tax on income of individuals; and (ii) the tax on income of legal persons;

(hereinafter referred to as “Czech tax”).

The Convention shall apply also to any identical or substantially similar taxes that are imposed after the date of signature of the Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes that have been made in their taxation laws.

ARTICLE 3

GENERAL DEFINITIONS

For the purposes of this Convention, unless the context otherwise requires:

a) the terms “a Contracting State” and “the other Contracting State” mean the Czech Republic or the Republic of Cameroon, as the context requires; b) the term “Cameroon” means the territory of the Republic of Cameroon, and when used in a geographical sense, includes the territorial sea and any area adjacent to the