Protocol

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.... paragraph 5 it is understood that in the case of India interest, royalties or fees for technical services shall be deemed to arise in a Contracting State if the payer is a political sub-division of that State. IN WITNESS WHEREOF, the undersigned, being duly authorized thereto, have signed this Protocol. DONE in duplicate at New Delhi, this thirteenth day of April, 1999, in Hindi, Kyrgyz, Russian and English languages, all four texts being equally authentic. In case of divergence between the texts, the English text shall prevail. 1[Whereas, the Protocol, amending the Agreement between the Government of the Republic of India and the Government of the Kyrgyz Republic for the avoidance of double taxation and for the prevention of fiscal eva....

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....ril, 1999 (hereinafter referred to as "the Agreement"). Have agreed as follows: Article 1 Subparagraph (ii) of paragraph (g) of Article 3 of the Agreement shall read as follows: "in Kyrgyz Republic, the Ministry of Economy or its authorized representative". Article 2 Article 26 of the Agreement shall be replaced by the following "ARTICLE 26 EXCHANGE OF INFORMATION 1. The competent authorities of the Contracting States shall exchange such information (including documents or certified copies of the documents) as is foreseeably relevant for carrying out the provisions of this Agreement or to the administration or enforcement of the domestic laws concerning taxes of every kind and description imposed on behalf of the Contracting States....

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....nts) which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State; (c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy. 4. If information is requested by a Contracting State in accordance with this Article, the other Contracting State shall use its information gathering measures to obtain the requested information, even though that other State may not need such information for its own tax purposes. The obligation contained in the preceding sentence is subject to the limitations of paragraph 3, but in no case shall such l....