The Finance Ministry has announced that the application of a part of the DTT with Belarus would be suspended from 1 June 2024 through 31 December 2026.
Belarus has withdrawn from the application of Article 10, 11, and 13 of the Double Tax Treaty between Czechia and Belarus, which concern the taxation of capital gains (dividends, interest, and divestment proceeds). In response to this Belarusian step, the Czech Finance Ministry announced, in Finance Bulletin 4/2024, that Articles 10, 11, and 13 of the Treaty will accordingly also not be applied in the Czech Republic within the aforementioned time period.
The Finance Ministry went on to inform that, as a consequence of the suspension of the said Articles, no situation may arise in which only one party to the treaty would be required to exclude double taxation. For this reason, Article 23 (on mutually applicable methods to avoid double taxation) will likewise be inoperative. Along the same lines, the dispute resolution methods afforded under Art. 25 will not be available.
On 1 July 2024, the fiscal administration published an in-depth memo on the consequences which the suspension of selected articles of the DTT will have, including practical examples from real-life situations.
Source:
Website of the Czech Finance Ministry: https://www.financnisprava.cz/cs/mezinarodni-spoluprace/mezinarodni-zdanovani-prime-dane/pokyny-sdeleni/2024/preruseni-provadeni-vybranych-clanku