Protocol

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..... lic of India and the Government of the Russian Federation for the avoidance of double taxation with respect to taxes on income signed today (in this Protocol called the Agreement ), 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 .....

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..... ears or such longer period as has been specified in the contract by the authority granting approval to the contract. The said time will include the further period 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 w .....

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..... rovided that in no case the differences in the two rates, referred to above will exceed 12 percentage points. The taxation of a permanent establishment 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 en .....

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