TaxTMI 
TaxTMI 
Protocol
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....n's share of any profits, income or gains of the partnership; any such share of profits, income or gains shall be treated for the purposes of Article 23 as profits, income or gains from sources in India and the appropriate part of the Indian tax borne by the partnership shall be allowed as a credit against any Irish tax computed by reference to the said share of the profits, income or gains. With reference to Article 7 2. If, in accordance with the laws of a Contracting State, profits are attributed to a permanent establishment of an enterprise carrying on insurance business, on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State from....
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....vergence 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, vide Notification No. GSR 212(E), dated 19-3-2002 In the Notification No. 45/2002 of the Government of India, in the Ministry of Finance (Department of Revenue), Number G.S.R. 105(E), dated the 20th February, 2002 published in the Gazette of India, (Extraordinary), in Part-II, section 3, sub-section (i), dated the 20th February, 2002, the Exchange of Letters between the Indian and the Irish authorities as annexed shall form part of the aforesaid notification. ANNEXURE The Department of Foreign Affairs presents its compliments to the Embassy of India and has the honour to refer to the Convention bet....
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....he Department of Foreign Affairs has the honour to suggest that the present Note and the reply of the Government of the Republic of India to that effect shall be regarded as constituting an agreement between the two Governments in this matter which shall enter into force at the same time as the entry into force of the Convention. The Department of Foreign Affairs avails itself of this opportunity to renew to the Embassy of India the assurances of its highest consideration. The Embassy of India, Dublin, presents its compliments to the Department of Foreign Affairs of the Government of Ireland and with reference to their Note Verbale No. 348/764, dated 3rd September, 2001, regarding the Convention for Avoidance of Double Taxation and the Pr....