9911796707
TMI BlogAgreement between the Government of the Republic of India and Government of Republic of India and the Government of Singapore for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxesX X X X Extracts X X X X X X X X Extracts X X X X ..... 022(E), Dated 18-7-2005; No. S.O. 2031(E), Dated 1-9-2011 and No. S.O. 935(E), Dated 23-3-2017 ANNEXURE AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDIA AND THE GOVERNMENT OF THE REPUBLIC OF SINGAPORE FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME The Government of the Republic of India and the Government of the Republic of Singapore, desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, Have agreed as follows: ARTICLE 1 PERSONAL SCOPE This Agreement shall apply to persons who are residents of one or both of the Contracting States. ARTICLE 2 TAXES COVERED 1. The taxes to which this Agreement shall apply are: (a) in India: income-tax including any surcharge thereon (hereinafter referred to as Indian tax ); (b) in Singapore: the income-tax (hereinafter referred to as Singapore tax ). 2. The Agreement shall also apply to any identical or substantially similar taxes which are imposed by either Contracting State after the date of signature of the present Agreement in addition to, or in place of, the taxes referred to in paragraph 1. T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... his Agreement applies or which represents a penalty imposed relating to those taxes. 2. As regards the application of the Agreement by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have, the meaning which it has under the law of that State concerning the taxes to which the Agreement applies. ARTICLE 4 RESIDENT 1. For the purposes of this Agreement, the term resident of a Contracting State means any person who is a resident of a Contracting State in accordance with the taxation laws of that State. 2. Where by reason of the provisions of paragraph 1, an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al year in connection with the exploration, exploitation or extraction of mineral oils in that Contracting State. 6. An enterprise shall be deemed to have a permanent establishment in a Contracting State if it furnishes services, other than services referred to in paragraphs 4 and 5 of this Article and technical services as defined in Article 12, within a Contracting State through employees or other personnel, but only if: (a) activities of that nature continue within that Contracting State for a period or periods aggregating more than 90 days in any fiscal year; or (b) activities are performed for a related enterprise (within the meaning of Article 9 of this Agreement) for a period or periods aggregating more than 30 days in any fiscal year. 7. Notwithstanding the preceding provisions of this Article, the term permanent establishment shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or occasional delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or occasional delivery; (c) the maintenance of a s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of an independent status within the meaning of this paragraph. 10. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other Contracting State (whether through a permanent establishment or otherwise shall not of itself constitute either company a permanent establishment of the other. ARTICLE 6 INCOME FROM IMMOVABLE PROPERTY 1. Income derived by a resident of a Contracting State from immovable property situated in the other Contracting State may be taxed in that other State. 2. The term immovable property shall have the meaning which it has under the law of the Contracting State in which the property in question is situated. The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural resources. Ships and aircraft shall ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Agreement, then the provisions of those Articles shall not be affected by the provisions of this Article. 8. For the purpose of paragraph 1, the term directly or indirectly attributable to the permanent establishment includes profits arising from transactions in which the permanent establishment has been involved and such profits shall be regarded as attributable to the permanent establishment to the extent appropriate to the part played by the permanent est ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in the profits of an enterprise of that State - and taxes accordingly - profits on which an enterprise of the other Contracting State has been charged to tax in that other State and the profits so included are profits which would have accrued to the enterprise of the first-mentioned State if the conditions made between the two enterprises had been those which would have been made between independent enterprises, then that other State shall make an appropriate adjustment to the amount of the tax charged therein on those profits. In determining such adjustment, due regard shall be had to the other provisions of this Agreement and the competent authorities of the Contracting States shall, if necessary, consult each other.] ************ NOTES: - 1. Existing paragraph re-numbered as paragraph 1 by Notification No. SO 935(E) [No.18/2017 (500/139/2002-FTD-II], dated 23-3-2017, w.r.e.f. 27-2-2017. 2. Paragraph 2 inserted by Notification No. SO 935(E) [No.18/2017 (500/139/2002-FTD-II], dated 23-3-2017, w.r.e.f. 27-2-2017. ARTICLE 10 DIVIDENDS 1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other Sta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th a permanent establishment or a fixed base situated in that other State, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State. 7. (a) Dividends shall be deemed to arise in India if they are paid by a company which is a resident of India; (b) Dividends shall be deemed to arise in Singapore: (i) if they are paid by a company which is a resident of Singapore; or (ii) if they are paid by a company which is a resident of Malaysia out of profits arising in Singapore and qualifying as dividends arising in Singapore under Article VII of the Agreement for the Avoidance of Double Taxation between Singapore and Malaysia signed on 26th December, 1968. ARTICLE 11 INTEREST 1. Interest arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such interest may also be taxed in the Contracting State in which it arises, and according to the laws of that State, but if the beneficial owner of the interest is a resident of the other Contracting Stat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ationship, the provisions of this Article shall apply to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. ARTICLE 12 ROYALTIES AND FEES FOR TECHNICAL SERVICES 1. Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 1[2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties or fees for technical services, the tax so charged shall not exceed 10 per cent.] 3. The term royalties as used in this Article means payments of any kind received as a consideration for the use of, or the right to use: (a) any copyright of a literary, artistic or scientific work, including cinematograph film or films or tapes used for radio or television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning indu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 7. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political sub-division, a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the liability to pay the royalties or fees for technical services was incurred, and such royalties or fees for technical services are borne by such ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y whose shares are being alienated is a resident at a tax rate that shall not exceed 50% of the tax rate applicable on such gains in that State. 5. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4A and 4B of this Article shall be taxable only in the Contracting State of which the alienator is a resident.] ********* NOTES: - 1. Paragraph 4 omitted by Notification No. SO 935(E) [No. 18/2017 (500/139/2002-FTD-II], dated 23-3-2017, w.e.f. 1-4-2017. Prior to its omission, said paragraph, as amended by Notification No. So, 1022(E), dated 18-7-2005, read as under: 4. Gains derived by resident of a Contracting State from the alienation of any property other than those mentioned in paragraphs 1, 2 and 3 of this Article shall be taxable only in that State. 2. Paragraphs 4A, 4B, 4C and 5 inserted by Notification No. SO 935(E) [No. 18/2017 (500/139/2002-FTD-II], dated 23-3-2017, w.e.f. 1-4-2017. ARTICLE 14 INDEPENDENT PERSONAL SERVICES 1. Income derived by an individual who is a resident of a Contracting State from the performance of professional services or other independent activities of a similar character shall be taxable only in that State exc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ot exceed 15 per cent of the gross amount of the remuneration. 4. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State. ARTICLE 16 DIRECTORS' FEES Directors' fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other State. ARTICLE 17 ARTISTES AND SPORTSPERSONS 1. Notwithstanding the provisions of Articles 14 and 15, income derived by a resident of a Contracting State as an artiste such as a theatre, motion picture, radio or television artiste or a musician or as a sportsperson, from his personal activities as such exercised in the other Contracting State may be taxed in that other State. 2. Where income in respect of or in connection with personal activities exercised by an artiste or a sportsperson accrues not to the artiste or sportsperson himself but to another person, that income may, notwithstanding the provisions of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... carried on by a Contracting State or a political sub-division or a local authority or a statutory body thereof. ARTICLE 19 NON-GOVERNMENT PENSIONS AND ANNUITIES 1. Any pension, other than a pension referred to in Article 18, or any annuity derived by a resident of a Contracting State from sources within the other Contracting State may be taxed only in the first-mentioned State. 2. The term pension means a periodic payment made in consideration of past services or by way of compensation for injuries received in the course of performance of services. 3. The term annuity means a stated sum payable periodically at stated times during life or during a specified or ascertainable period of time, under an obligation to make the payments in return for adequate and full consideration in money or money's worth. ARTICLE 20 STUDENTS AND TRAINEES 1. An individual who is or was a resident of a Contracting State immediately before making a visit to the other Contracting State and is temporarily present in the other State solely: (a) as a student at a recognised university, college, school or other similar recognised educational institution in that other State; (b) as a business or technical ap ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of Singapore and shall include: (i) the Monetary Authority of Singapore and the Board of Commissioners of Currency; (ii) the Government of Singapore Investment Corporation Pvt. Ltd. to the extent it is not engaged in the conduct of commercial activities; (iii) a statutory body not engaged in the conduct of commercial activities; (iv) any other institution or body as may be agreed from time to time between the competent authorities of the Contracting States; (b) in the case of India means the Government of India and shall include: (i) the Governments of the States and the Union Territories of India; (ii) the Reserve Bank of India or any of its subsidiaries which is not engaged in the conduct of commercial activities; (iii) a statutory body not engaged in the conduct of commercial activities; (iv) any other institution or body as may be agreed from time to time between the competent authorities of the Contracting States. ARTICLE 23 INCOME NOT EXPRESSLY MENTIONED Items of income which are not expressly mentioned in the foregoing Articles of this Agreement may be taxed in accordance with the taxation laws of the respective Contracting States. ARTICLE 24 LIMITATION OF RELIEF 1. Where t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... annual expenditure on operations in that Contracting State is equal to or more than S$ 200,000 in Singapore or Indian Rs. 5,000,000 in India, as the case may be: (i) in the case of paragraph 4A of Article 13 of this Agreement, for each of the 12-month periods in the immediately preceding period of 24 months from the date on which the gains arise; (ii) in the case of paragraph 4C of Article 13 of this Agreement, for the immediately preceding period of 12 months from the date on which the gains arise. 5. For the purpose of paragraph 4(a) of this Article, a recognised stock exchange means: (a) in the case of Singapore, the securities market operated by the Singapore Exchange Limited, Singapore Exchange Securities Trading Limited and The Central Depository (Pte) Limited; and (b) in the case of India, a stock exchange recognised by the Securities and Exchange Board of India. Explanation: The cases of legal entities not having bona fide business activities shall be covered by paragraph 1 of this Article.] ********** NOTES: - 1. Article 24A inserted by Notification No. SO 935(E) [No.18/2017 (500/139/2002-FTD-II], dated 23-3-2017, w.e.f. 1-4-2017. ARTICLE 25 AVOIDANCE OF DOUBLE TAXATION 1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... be allowed as a credit against Singapore tax payable in respect of that income. Where such income is a dividend paid by a company which is a resident of India to a resident of Singapore which owns not less than 25 per cent of the share capital of the company paying the dividends, the credit shall take into account Indian tax paid in respect of its profits by the company paying the dividends. 5. For the purposes of paragraph 4 of this Article the term Indian tax paid shall be deemed to include any amount of tax which would have been payable in India but for a deduction allowed in computing the taxable income or an exemption or reduction of tax granted for that year in question: (a) Sections 10( 4), 10(4B), 10(5B), 10(15 )(iv), 10A, 10B, 33AB, 80-I and 80-IA, insofar as these provisions were in force and have not been modified since the date of signature of this Agreement, or have been modified only in minor respects so as not to affect their general character, (b) any other provision which may subsequently be enacted granting an exemption or reduction of tax which is agreed by the competent authorities of the Contracting States to be of a substantially similar character to a provis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Contracting States regarding the imposition of tax on non-resident persons as such; (c) obliging a Contracting State to grant to nationals of the other Contracting State those personal allowances, reliefs, reductions and deductions for tax purposes which it grants to its own citizens who are not resident in that State or to such other persons as may be specified in the taxation laws of that State; and (d) affecting any provisions of the tax laws of the respective Contracting States regarding any tax concessions granted to persons fulfilling specified conditions. 5. In this Article, the term taxation means taxes which are the subject of this Agreement. ARTICLE 27 MUTUAL AGREEMENT PROCEDURE 1. Where a resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with this Agreement, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. This case must be presented within three years of the date of receipt of notice of the action which gives rise to taxation not i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3. In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose on a Contracting State the obligation: (a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State; (b) to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State; (c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information the disclosure of which would be contrary to public policy (ordre public). 4. If information is requested by a Contracting State in accordance with this Article, the other Contracting State shall use its information gathering measures to obtain the requested information, even though that other State may not need such information for its own tax purposes. The obligation contained in the preceding sentence is subject to the limitations of paragraph 3 but in no case shall such limitations be construed to permit a Contracting State to decline to supply information solely because it has no domestic interest in such information. 5. In ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... S This Agreement shall not prevent a Contracting State from applying its domestic law and measures concerning the prevention of tax avoidance or tax evasion. ARTICLE 6 Each of the Contracting States shall complete the procedures required by its law for the bringing into force of this Protocol and notify the other State about such completion of the procedures. This Protocol shall enter into force on the date of the later of these notifications. If this Protocol does not enter into force as at 31 March 2017 due to either of the aforesaid notifications remaining pending, this Protocol shall enter into force on 1 April 2017. ARTICLE 7 This Protocol, which shall form an integral part of the Agreement, shall remain in force as long as the Agreement remains in force and shall apply as long as the Agreement itself is applicable.] ************** NOTES: - 1. Article 28A inserted by Notification No. SO 935(E) [No.18/2017 (500/139/2002-FTD-II], dated 23-3-2017, w.r.e.f. 27-2-2017. ARTICLE 29 DIPLOMATIC AND CONSULAR OFFICIALS Nothing in this Agreement shall affect the fiscal privileges of diplomatic or consular officials under the general rules of international law or under the provisions of sp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... col amending the Agreement for giving effect to the provisions of the said Protocol; Now, therefore, in exercise of the powers conferred by section 90 of the Income-tax Act, 1961 (43 of 1961), the Central Government hereby directs that all the provisions of the said Protocol amending the Agreement between the Government of the Republic of India and the Government of the Republic of Singapore for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income shall be given effect to in the Union of India with effect from the 1st day of August, 2005. ANNEXURE PROTOCOL AMENDING THE AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDIA AND THE GOVERNMENT OF THE REPUBLIC OF SINGAPORE FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME SIGNED IN INDIA ON 24TH JANUARY, 1994 The Government of the Republic of India and the Government of the Republic of Singapore, Desiring to conclude a Protocol to amend the Agreement between the Government of the Republic of India and the Government of the Republic of Singapore for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ESPECT TO TAXES ON INCOME The Government of the Republic of India and the Government of the Republic of Singapore, Desiring to conclude a Second Protocol to amend the Agreement between the Government of the Republic of India and the Government of the Republic of Singapore for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, signed at India on 24 January, 1994, as amended by the Protocol signed at India on 29 June, 2005 (hereinafter referred to as the Agreement ), Have agreed as follows: Article 1 Article 28 of the Agreement shall be deleted and replaced by: ARTICLE 28 EXCHANGE OF INFORMATION 1. The competent authorities of the Contracting States shall exchange such information as is foreseeably relevant for carrying out the provisions of this Agreement or to the administration or enforcement of the domestic laws concerning taxes of every kind and description imposed on behalf of the Contracting States, or of their political sub-divisions or local authorities, insofar as the taxation thereunder is not contrary to the Agreement. The exchange of information is not restricted by Articles 1 and 2. 2. Any information received under pa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ol. This Protocol shall enter into force on the first day of the month after the date of the latter of these notifications. The provisions of this Protocol shall apply to taxes relating to taxable periods beginning on or after 1 January of the three calendar years immediately preceding the calendar year of the entry into force of this Protocol. Article 4 This Protocol, which shall form an integral part of the Agreement, shall remain in force as long as the Agreement remains in force and shall apply as long as the Agreement itself is applicable. IN WITNESS WHEREOF, the undersigned, duly authorised thereto by their respective Governments, have signed this Protocol. DONE in duplicate at New Delhi on this 24th day of June, 2011, in the Hindi and English languages, both texts being equally authentic. In the case of divergence between the two texts, the English text shall be the operative one. Whereas, a Third Protocol amending the Agreement between the Government of the Republic of India and the Government of the Republic of Singapore for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income was signed at New Delhi on the 30th day of Decem ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... this Agreement and the competent authorities of the Contracting States shall, if necessary, consult each other. ARTICLE 2 Article 13 - Capital Gains of the Agreement shall be amended, with effect from 1 April 2017: (i) by deleting paragraph 4; and (ii) by inserting the following paragraphs: 4A. Gains from the alienation of shares acquired before 1 April 2017 in a company which is a resident of a Contracting State shall be taxable only in the Contracting State in which the alienator is a resident. 4B. Gains from the alienation of shares acquired on or after 1 April 2017 in a company which is a resident of a Contracting State may be taxed in that State. 4C. However, the gains referred to in paragraph 4B of this Article which arise during the period beginning on 1 April 2017 and ending on 31 March 2019 may be taxed in the State of which the company whose shares are being alienated is a resident at a tax rate that shall not exceed 50% of the tax rate applicable on such gains in that State. 5. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4A and 4B of this Article shall be taxable only in the Contracting State of which the alienator is a r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (b) in the case of India, a stock exchange recognised by the Securities and Exchange Board of India. Explanation: The cases of legal entities not having bona fide business activities shall be covered by paragraph 1 of this Article. ARTICLE 4 Articles 1, 3, 5 and 6 of the 2005 Protocol shall be deleted, with effect from 1 April 2017. ARTICLE 5 The Agreement is amended by adding after Article 28, the following Article: ARTICLE 28A MISCELLANEOUS This Agreement shall not prevent a Contracting State from applying its domestic law and measures concerning the prevention of tax avoidance or tax evasion. ARTICLE 6 Each of the Contracting States shall complete the procedures required by its law for the bringing into force of this Protocol and notify the other State about such completion of the procedures. This Protocol shall enter into force on the date of the later of these notifications. If this Protocol does not enter into force as at 31 March 2017 due to either of the aforesaid notifications remaining pending, this Protocol shall enter into force on 1 April 2017. ARTICLE 7 This Protocol, which shall form an integral part of the Agreement, shall remain in force as long as the Agreement re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ve Contracting State as the case may be, in the immediately preceding period of 24 months from the date the gains arise. 4. A resident of a Contracting State is deemed not to be a shell/conduit company if (a) it is listed on a recognised stock exchange 3 of the Contracting State; or (b) its total annual expenditure on operations in that Contracting State is equal to or more than S$200,000 or Indian Rs. 50,00,000 in the respective Contracting State as the case may be, in the immediately preceding period of 24 months from the date the gains arise. Explanation: The cases of legal entities not having bona fide business activities shall be covered by Article 3.1 of this Protocol. 4. 4. Article 5 omitted by Notification No. SO 935(E) [No.18/2017 (500/139/2002-FTD-II], dated 23-3-2017, w.e.f. 1-4-2017. Prior to its omission, said Article read as under: ARTICLE 5 - It is agreed that there shall be an inter-governmental group consisting of representatives of the revenue authorities of the two Contracting States which shall review the working of the provisions of this Protocol at least once a year or earlier at the request of either Contracting State and may make recommendations for improvem ..... X X X X Extracts X X X X X X X X Extracts X X X X
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