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Tax treaty protocol: Protocol is integral to the DTAA and forms part of the treaty's Article framework. The Protocol attached to the Double Taxation Avoidance Agreement is an integral component of the treaty and its provisions are to be read with and give effect to the Agreement, thereby governing the application and implementation of the treaty's Articles, including the provision identified as Article 13, between Guernsey and the other Contracting State.
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Provisions expressly mentioned in the judgment/order text.
Tax treaty protocol: Protocol is integral to the DTAA and forms part of the treaty's Article framework.
The Protocol attached to the Double Taxation Avoidance Agreement is an integral component of the treaty and its provisions are to be read with and give effect to the Agreement, thereby governing the application and implementation of the treaty's Articles, including the provision identified as Article 13, between Guernsey and the other Contracting State.
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