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.... shall constitute an integral part thereof: 1. Ad Articles 5, 7 and 12 If under any Convention or Agreement between India and a third State being a member of the OECD which enters into force after 1st January, 1990, India limits its taxation on royalties or fees for technical services to a rate lower or a scope more restricted than the rate or scope provided for in  the present Agreemen....

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....e in which a permanent establishment is situated imposes in accordance with the provisions of the first sentence of sub paragraph (a) of paragraph 3 of Article 7 a restriction on the amount of the executive and general administrative expenses which may be allowed as deductions in determining the profits of such permanent establishment, it is understood that in determining the profits of such perma....