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TMI BlogProtocolX X X X Extracts X X X X X X X X Extracts X X X X ..... the context requires, but shall not include any amount which is payable in respect of any default or omission in relation to the taxes to which this Agreement applies or which represents a penalty or fine imposed relating to those taxes. Further, the amounts payable for the aforementioned default, omission, penalty or fine shall not be taken into account for giving tax credit. 2. For the purpose of computing the time limit in paragraph 3 (a) of Article 5, the period of 270 days begins on the date on which the construction activity itself begins. It does not take into account the time spent solely on preparatory activities such as obtaining permits or licences. 3. With reference to paragraph 3 of Article 8 it is understood that: Profits der ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... paragraph 3 of Article 7. It is also understood that in no case the taxation of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall be less favorably levied than the taxation levied on a permanent establishment of an enterprise of a third State carrying on the same activities under a double taxation Agreement concluded by the other Contracting State with that third State. 8. With reference to Article 27 (Exchange of Information), it is understood that: a) An exchange of information will only be requested once the requesting Contracting State has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... equested State, the requesting State will bear the excessive costs, as may be mutually agreed upon between the competent authorities of the Contracting States. f) The requested State shall be required to ensure that the data to be supplied is accurate. If it emerges that inaccurate data has been supplied, the requesting State shall be informed of this without delay. That State shall be required to correct such data without delay. g) The requested and the requesting States shall be required to take effective measures to protect the information supplied against unauthorised access, alteration and disclosure. 9. It is understood that when Iran introduces a provision in its domestic law regarding assistance in collection of taxes to other treat ..... X X X X Extracts X X X X X X X X Extracts X X X X
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