Protocol

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..... to sub-paragraph (c) of paragraph 1 of Article 3 1. The term "tax" 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. With respect to proviso to sub-paragraph (j) of paragraph 2 of Article 5 2. It is understood that an enterprise covered therein will be subject to .....

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..... lishment. With respect to paragraph 3 of Article 7 4. With regard to a permanent establishment in India, it is understood that, the executive and general administrative expenses incurred outside India which will be allowed as a deduction in determining the profits of the permanent establishment shall be the least of the following amounts: (a) an amount equal to 5 per cent of the adjusted total .....

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..... o taxpayers (individuals, legal persons, partnerships and associations) placed from the point of view of the application of the ordinary taxation laws and regulations, in substantially similar circumstances both in law and in fact. Amongst other things this means that a national of one of the States, resident of a third State and doing business in the other State will be subjected to the same tax .....

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