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..... ginning after the expiration of five years from the date of entry into force of the Agreement. In such event, the Agreement shall cease to have effect: (a) in India, in respect of income derived in any fiscal year on or after the first day of April next following the calendar year in which the notice is given; (b) in Latvia: (i) in respect of taxes withheld at source, on income derived on or after .....

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..... axation and the prevention of fiscal evasion with respect to taxes on income (hereinafter referred to as the Agreement ) the undersigned have agreed upon the following provisions with purpose to clarify the application of the Agreement. 1. With reference to Article 5: It is understood that on the date of signature of this Agreement none of the agreements for the avoidance of double taxation conclu .....

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..... tivities of a purely preparatory or auxiliary character. 3. With reference to paragraph 3 of Article 5: It is understood that the supervisory activities or services referred to in paragraph 3 of Article 5 does not include activities or services covered under sub-paragraph (b) of paragraph 3 of Article 12. Done in duplicate at New Delhi this 18th day of September, 2013, each in the Hindi, Latvian a .....

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