Protocol

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....Article 3 For the purposes of paragraph 3, the reference to the time of application of the Convention shall mean the time when the income which is the subject-matter of this Convention arises. Ad Article 3 and 23 For the purposes of paragraph 1(d), of Article 3 and Article 23, the expression tax shall not include any amount which is payable in respect of any default or omission in relatio....

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....s favourable than those in force on the date of the signing of this Convention. Ad Article 13 For the purposes of paragraphs 1 and 4, it is agreed that the Contracting State of which the person deriving the capital gains is a resident is also entitled to tax such capital gains. Ad Article 23 It is understood that the term economic development used in paragraph 5 of Article 23 would mea....

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....the first-mentioned Contracting State subject to the difference between the two rates not being more than 10%. ^1[Ad article 26 The supplying and the receiving agencies shall be obliged to take effective measures to protect the personal data supplied against unauthorized access, unauthorized alteration and unauthorized disclosure] In witness whereof, the undersigned, duly authorised there....