Protocol

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....e Agreement. 1. With reference to sub-paragraph (b) of paragraph 2 of Article 10, it is understood that, under the full imputation system adopted by Malta, there is no withholding tax on dividends in addition to the tax chargeable in respect of the profits or income of the company out of which the dividends are paid. 2. The provisions of Articles 6 to 22 of the Agreement shall not apply to: a)....

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.... after the date of signature of this Agreement, the laws of Malta change to provide assistance in collection of taxes to any country which is not a member of the European Union or Malta agrees to extend such assistance to any country which is not a member of the European Union, then Malta shall forthwith inform the Indian competent authority and the competent authorities of the Contracting States ....