Protocol

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..... r the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, the undersigned have agreed that the following provisions shall form an integral part of the Agreement: I. Ad Article 2 Paragraph 2 The Icelandic social security charge Tryggingargjald shall not be regarded as taxes on the total amounts of wages or salaries paid by enterprises. II. Ad Article 8 .....

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..... oyalties and Fees for Technical Services), or 13 (Capital Gains) if: a) By reason of special measures, the tax imposed on such corporation by the first-mentioned Contracting State with respect to such dividends, interest, royalties, or capital gains is substantially less than the tax generally imposed by such Contracting State on corporate profits; and b) 25 per cent or more of the capital of such .....

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..... differences in the two rates, referred to above will exceed 10 percentage points. IN WITNESS whereof the undersigned, duly authorized thereto, have signed this Protocol. DONE in duplicate at New Delhi on this Twenty-third Day of November, 2007, each in the Hindi, Icelandic and English languages, all texts being equally authentic. In case of divergence of interpretation, the English text shall pre .....

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