Protocol - Protocol - Nepal

PROTOCOL At the moment of signing of the Agreement this day concluded between the Government of the Republic of India and the Government of Nepal for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, the undersigned have agreed upon the following provisions which shall be an integral part of the Agreement: 1. It is understood that if the domestic law of a Contracting States is more beneficial to resident of the other Contracting State than the provision of this Agreement, then the provisions of the domestic law of the first mentioned State shall apply to the extent they are more beneficial to such a resident. 2. With reference to Article 12: In respect to Article. 12 (Royalties) if under any Agreement Convention or Protocol between Nepal and a third State, Nepal limits its taxation at source on royalties to a rate lower or a scope more restricted than the rate or scope provided for in this Agreement on Royalties, then as from the date on which the relevant Nepal Agreement or Convention or protocol enters into force, the same rate of scope as provided for in that Agreement or Convention or Protocol on Royalties shall also apply under this Agreement. IN WITNESS WHEREOF the undersigned, duly authorized thereto have signed this Agreement. DONE in duplicate; at Kathmandu on this 27th day of November, 2011, each in the Hindi, Nepali and English languages, all texts being equally authentic. In case of divergence of interpretation, the English text shall prevail. For the Government of the Republic of India For the Government of Nepal (PRANAB MUKHERJEE) MINISTRY OF FINANCE (BARSHA MAN PUN) MINISTRY OF FINANCE