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....vention: Ad Articles 6 and 13: With reference to paragraph 1 of Article 6 and Article 13 it is understood that in the case of India income from immovable property and capital gains on alienation of immovable property respectively may be taxed in both Contracting States subject to the provisions of Article 23 paragraph 3. Ad Article 7: (a) It is understood that the deductions in respect of the ....

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....st mentioned State at a rate of tax which is higher than that imposed on the profits of a similar company of the first-mentioned Contracting State, nor being in conflict with the provisions of paragraph 3 of Article 7. However, the difference in tax rate shall not exceed 15 percentage points. Ad Article 26: It is understood that in the case of disclosure of information referred to in paragraph 1 ....