Article PROTOCOL - Protocol - Kyrgyz Republic

PROTOCOL At the signing of the Agreement between the Government of the Republic of India and the Government of the Kyrgyz Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, the undersigned have agreed that the following shall form an integral part of the Agreement. 1. With reference to Article 6 it is understood that income from immovable property may be taxed in both the Contracting States. 2. With reference to Article 11 paragraph 3(i) it is understood that Government in the case of India shall include a political sub-division. 3. With reference to Article 11 paragraph 6 and Article 12 paragraph 5 it is understood that in the case of India interest, royalties or fees for technical services shall be deemed to arise in a Contracting State if the payer is a political sub-division of that State. In witness whereof, the undersigned, being duly authorized thereto, have signed this Protocol. Done in duplicate at New Delhi, this thirteenth day of April, 1999, in Hindi, Kyrgyz, Russian and English languages, all four texts being equally authentic. In case of divergence between the texts, the English text shall prevail.