Taxation of residents: States may tax their citizens residing abroad without treaty credit for such domestic taxes. The Protocol preserves each Contracting State's right to tax its citizens resident in the other State without treaty credit, limits deductions for expenses incurred abroad in line with domestic law for Article 7(3), treats the tax rates in Articles 8 and 9 as inclusive of any Branch Profit Remittance Tax, and requires the Philippines to notify India and review Articles 8 and 9 if it grants lower or nil rates to a third State for comparable profits.