Protocol

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Convention: With reference to Articles 3 and 23 1. Where a person resident in Ireland is a member of a partnership which is resident in India and by virtue of this Convention any profits, income or gains of the partnership are relieved from tax in Ireland, the Convention shall not affect any liability to tax in Ireland of such person in respect of such person's share of any profits, inco....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....tionment adopted shall, however, be such that the result shall be in accordance with the principles contained in Article 7. With reference to Article 24 3. The provisions of this Article shall not be construed as preventing India from charging the profits of a permanent establishment of an Irish company in India at a rate of tax which is higher than that imposed on the profits of a similar I....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....n witness whereof the undersigned, being duly authorised thereto, have signed this Convention. Done in duplicate at New Delhi on this 6th day of November in 2000, in the Hindi and English languages, both the texts being equally authentic. In case of divergence between the two texts, the English text shall prevail. Addendum to Notification No. 45/2002 [F. No. 503/6/99-FTD], dated 20-2-2002, v....