Protocol

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..... tute an integral part thereof: 1. Ad Articles 5, 7 and 12 If under any Convention or Agreement between India and a third State being a member of the OECD which enters into force after 1st January, 1990, India limits its taxation on royalties or fees for technical services to a rate lower or a scope more restricted than the rate or scope provided for in the present Agreement on the said items of in .....

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..... nt is situated imposes in accordance with the provisions of the first sentence of sub paragraph (a) of paragraph 3 of Article 7 a restriction on the amount of the executive and general administrative expenses which may be allowed as deductions in determining the profits of such permanent establishment, it is understood that in determining the profits of such permanent establishment the deduction i .....

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..... end the Agreement, if necessary. IN WITNESS WHEREOF the undersigned, being duly authorised thereto, have signed the present Protocol. Done in duplicate at Brussels this 26th day of April one thousand nine hundred and ninety-three, in the Hindi, English, French and Dutch languages, all four texts being equally authentic. In case of divergence of interpretation, the English text shall prevail. For t .....

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