Most favoured nation clause extends lower royalty and technical service tax terms from OECD treaties to this DTAA.

The Protocol adds a most favoured nation rule applying more favourable royalty and fees for technical services taxation from later OECD member conventions; requires Belgium to allow deductions for executive and general administrative expenses reasonably allocable to an Indian enterprise's Belgian permanent establishment, with a floor equal to amounts allowable at signature; and mandates mutual notification and consultation between competent authorities where domestic law later amends tax credit or reduction rules, with English prevailing among authenticated language texts.

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