Protocol

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.... Agreement"), Have agreed as follows : 1. With reference to paragraph 4 of Article 8 of the Agreement, the Contracting States agree that at the end of three years from the date of entry into force of this Agreement, the provisions of paragraph 4 will cease to have effect. 2. With respect to clause (j) of paragraph 2 of Article 5 of the Agreement, the competent authorities of t....

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....to the contract. The said time will include the further period which may be extended by the project approving authority in consultation with the competent authority of the concerned Contracting State; and (f) the enterprise is not involved in avoidance or evasion of tax in the Contracting State in which supervisory activities are being rendered. Where aforementioned conditions of sub....

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....ill exceed 12 percentage points. The taxation of a permanent establishment of an enterprise of one Contracting State in the other Contracting State shall not, after the coming into force of this Agreement, be less favourable than the tax treatment given by that other Contracting State to a permanent establishment of an enterprise of any third country. This Protocol shall form an integral par....