Protocol

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....Agreement: 1. With reference to paragraph 3 of Article 5, its understood that, for the purposes of computing the time limits referred to in that paragraph, such activities performed by an enterprise related to another enterprise within the meaning of Article 9, shall be added to the period during which activities are performed by the enterprise, provided that the activities of both enterprises ar....

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....ents as consideration for provision of services of technical or other personnel in accordance with the provisions of section 9 of the Income-tax Act, 1961. 4. It is understood that if the domestic law of a Contracting State is more beneficial to a resident of the other Contracting State than the provisions of this Agreement, then the provisions of the domestic law of the first-mentioned State sha....