Protocol

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....ndian or Saudi tax, as the context requires, but shall not include any penalty or fine imposed relating to those taxes. 3. For the purposes of Article 3, the term "fiscal year" means: (i) in the case of India: the financial year beginning on the 1st day of April; (ii) in the case of Saudi Arabia: taxable year as determined in the law and regulation of the Kingdom of Saudi Arabia. 4. It is understood that for the purposes of para 1(b) Article 4, the term 'resident' shall include: (a) the legal institutions and agencies of the Government, wholly owned directly, and controlled by the Government. (b) In the case of the Kingdom of Saudi Arabia, an individual who is an Indian national and is present in the Kingdom of S....

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....hall not be taxed in that other Contracting State. Where export contracts include other activities carried on in the other Contracting State, profits derived by the Permanent Establishment from such activities may be taxed in the other Contracting State but only so much of the profits as is attributable to the permanent establishment, relating to such other activities and any portion of these activities executed outside the other Contracting State shall not be taken into consideration in determining the profits of the permanent establishment. (ii) In the case of contracts for survey, constructions or installations, the profits of a permanent establishment shall not be determined on the total amount of the contract, but shall be determined....