Protocol

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..... shall be an integral part of the Agreement. 1. For the purpose of computing the time limit in paragraph 3 (a) of Article 5, the 270 days period begins as of the date on which the construction activity itself begins; it does not take into account the time spent solely on preparatory activities. 2. With respect to Article 7: - Where an enterprise of a Contracting State sells goods or merchandise or .....

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..... is effectively carried out by the permanent establishment in the State where the permanent establishment is situated. The profits related to that part of the contract which is carried out by the head office of the enterprise shall be taxable only in the State of which the enterprise is a resident. 3. It is understood that the two Contracting States will review the provisions of this Agreement aft .....

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..... neficial to such a resident. 6. When Myanmar introduces a provision in its domestic law regarding assistance in collection of taxes to other treaty partners or agrees to extend such assistance to any other treaty partner, then the competent authorities of the two Contracting States shall extend assistance in the collection of taxes to each other. In witness whereof, the undersigned, being duly aut .....

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