Protocol

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..... hall form an integral part of the said Agreement. (i) In respect of paragraphs 1 and 2 of Article 7, it is understood that where an enterprise of a Contracting State sells goods or merchandise or carries on business in the other Contracting State through a permanent establishment situated therein, the profits of that permanent establishment shall not be determined on the total amount received by t .....

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..... of the other Contracting State, then such more beneficial provisions of the domestic law shall prevail over the provisions of this Agreement. (iii) It is understood that, in respect of Article 10 on 'Dividends' the rate of withholding agreed to at 7.5% will be subject to review after three years from the date the Agreement enters into force. In case this rate is not reviewed after 3 years .....

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