Protocol

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..... quot;), Have agreed as follows : 1. With reference to paragraph 4 of Article 8 of the Agreement, the Contracting States agree that at the end of three years from the date of entry into force of this Agreement, the provisions of paragraph 4 will cease to have effect. 2. With respect to clause (j) of paragraph 2 of Article 5 of the Agreement, the competent authorities of the Contracting States .....

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..... eriod which may be extended by the project approving authority in consultation with the competent authority of the concerned Contracting State; and (f) the enterprise is not involved in avoidance or evasion of tax in the Contracting State in which supervisory activities are being rendered. Where aforementioned conditions of sub-paragraphs (a) to (f) of this paragraph are fulfilled, the enterpris .....

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..... of an enterprise of one Contracting State in the other Contracting State shall not, after the coming into force of this Agreement, be less favourable than the tax treatment given by that other Contracting State to a permanent establishment of an enterprise of any third country. This Protocol shall form an integral part of the Agreement. Done at Moscow, this 25th day of March, 1997, in duplicate .....

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