Article 11(1) provides that interest arising in Czechoslovakia
to a United Kingdom resident who is the beneficial owner of the
income is taxable only in the United Kingdom.
However, Czechoslovakia retains its taxing rights over the
interest if it is effectively connected (see INTM153110 fifth
sub-paragraph) with a permanent establishment or fixed base which
the United Kingdom resident recipient has in Czechoslovakia. In
such a case, the provisions of the Business profits Article or the
Independent personal services Article, as appropriate, will
apply.
