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of <h1>Protocol clarifies 'State' under Article 11(3): central bank/export-import bank and sovereign investment authority/holding company, executed in duplicate</h1> A protocol to the income tax double taxation agreement clarifies that for purposes of Article 11(3) the term 'State' includes, for one Contracting State, its central bank and export-import bank, and for the other Contracting State, its sovereign investment authority and a state-owned holding company. The protocol was executed in duplicate in New Delhi on 18 February 2025, with texts in Arabic, Hindi and English (English prevailing in case of divergence), and signed by duly authorized government representatives.
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