Protocol

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....wo Governments have agreed upon the following provisions which shall form an integral part of the Agreement: 1. For the purposes of the Agreement, it is understood that in relation to the Hong Kong Special Administrative Region, the terms "ordinarily resides" and "normally managed or controlled" have the meaning they have under the law of the Hong Kong Special Administrative Region as amended f....

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....ly managed or controlled in the Hong Kong Special Administrative Region if its executive officers and senior management employees make day-to-day key decisions in the Hong Kong Special Administrative Region for the strategic, financial and operational policies for the company or the person, and the staff of the company or the person conduct in the Hong Kong Special Administrative Region, the day-t....

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....reference to clause (i) of subparagraph (a) of paragraph 1 of Article 3 (General Definitions) of the Agreement, it is understood that the term "any place where the tax laws of the Hong Kong Special Administrative Region of the People's Republic of China apply" refers to the land and sea comprised within the boundary of the Hong Kong Special Administrative Region of the People's Republic of Chi....

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....taxes covered by the Agreement, the provisions of this Article also apply to the following taxes that are administrated and enforced in India: (i) the wealth tax; (ii) the excise and customs duties; (iii) the goods and services tax (GST); and (iv) the sales and value added taxes. 6. It is understood that the Contracting Parties may review the provisions of th....