Article Protocol - Protocol - Syrian Arab Republic

PROTOCOL The Government of the Republic of India and the Government of the Syrian Arab Republic, on signing at New Delhi on the 18 day of June, 2006 the Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes or income have agreed upon the following provisions which shall form an integral part of the said Agreement: 1. For the purposes of paragraph 3 of Article 4, it is clarified that in cases where the State in which the place of effective management of a person (other than an individual) is situated cannot be determined, then the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement. 2. With reference to paragraph 2 of Article 24, it is understood that this provision shall not be construed as preventing a Contracting State from charging the profits of a permanent establishment, which a company of the other Contracting State has in the first-mentioned State, within the framework of provisions of domestic law of the first mentioned Contracting State, nor as being in conflict with the provisions of paragraph 3 of article 7. 3. With reference to Article 26 on Exchange of information , it is understood that on a request made by a Contracting State, the competent authority of the other Contracting State shall give necessary information, for carrying out the provisions of this Agreement or of the domestic laws concerning taxes of every kind and description imposed on behalf of the Contracting State, or of their political subdivisions or local authorities, to the competent authority of the first mentioned State, which it can obtain under its domestic laws. 4. With reference to collection assistance, it is understood that if after the date of signature of this Agreement, Syria enters into an arrangement with another country to permit such assistance in collection, then Syria shall inform the Indian competent authority and shall immediately enter into negotiations for the purpose of incorporating provisions with regard to collection assistance in this Agreement. For the Government of the Republic of India: (PRANAB MUKHERJEE) EXTERNAL AFFAIRS MINISTER For the Government of the SyrianArabRepublic: DR. AMER HUSNI LUTFI MINISTER OF ECONOMY AND TRADE