Protocol

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....cting State. 2. With reference to paragraph 1 of Article 7, it is understood that where a permanent establishment which an enterprise of a Contracting State has in the other Contracting State, participates, itself or together with other parts of that enterprise or with an associated enterprise, in the negotiation, conclusion or fulfilment of a contract entered into by that enterprise or associated enterprise, there shall be attributed to the permanent establishment that portion of the profits of the contract arising in the other State as relates to the contribution by the permanent establishment to the negotiation, conclusion or fulfilment of the contract. 3. With reference to paragraph 3 of Article 7, it is agreed that th....

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.... THE GOVERNMENT OF THE REPUBLIC OF SOUTH AFRICA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME, SIGNED AT NEW DELHI ON 4 DECEMBER 1996 PREAMBLE The Government of the Republic of South Africa and the Government of the Republic of India; DESIRING to amend the Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, signed at New Delhi on 4 December 1996 (hereinafter referred to as "the Agreement"); HAVE AGREED AS FOLLOWS: ARTICLE I Article 25 of the Agreement shall be deleted and replaced by the following: "ARTICLE 25 EXCHANGE OF INFORMATION 1. The competent authorities of the....

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....State the obligation: (a)   to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State; (b)   to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State; (c)   to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information the disclosure of which would be contrary to public policy (ordre public). 4. If information is requested by a Contracting State in accordance with this Article, the other Contracting State shall use its information gatheri....