Protocol

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....article 3 For the purposes of paragraph 3, the reference to the time of application of the Convention shall mean the time when the income which is the subject-matter of this Convention arises. Ad articles 3 and 23 For the purposes of paragraph 1, d), of article 3 and article 23, the expression "tax" shall not include any amount which is payable in respect of any default or omission in rel....

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....ot be less favourable than those in force on the date of the signing of this Convention. Ad article 13 For the purposes of paragraphs 1 and 4, it is agreed that the Contracting State of which the person deriving the capital gains is a resident is also entitled to tax such capital gains. Ad article 23 It is understood that the term "economic development" used in paragraph 5 of article 2....

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....r company of the first-mentioned Contracting State subject to the difference between the two rates not being more than 10%. ^1[Ad article 26 The supplying and the receiving agencies shall be obliged to take effective measures to protect the personal data supplied against unauthorised access, unauthorised alteration and unauthorised disclosure.] IN WITNESS whereof, the undersigned, duly au....