Protocol

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..... reement: (I). It is understood that the last sentence of paragraph 1 of Article 4 (Resident) does not exclude from the scope of this agreement, any person who is liable to tax, in the Oriental Republic of Uruguay by virtue of the application of the principle of territorial source. (II). With reference to Article 8(Shipping and Air Transport), it is understood that, profits derived by a transportat .....

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..... . (IV). With reference to Article 8 (Shipping and Air Transport) and Article 13(Capital gains), it is understood that notwithstanding anything contained therein read with the domestic law of the Contracting States lead to a situation where an income is not taxable in the resident State, the source State shall retain the right to tax such income (V). It is understood that the provisions of Article .....

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..... s of Article 27 (Exchange of Information) shall have effect, relating to any fiscal year, next following the calendar year in which the Agreement enters into force. IN WITNESS WHEREOF, the undersigned, being duly authorized by their respective Governments, have signed this Protocol. Done in duplicate at New Delhi, this 8th day of September, 2011, in the English, Spanish and Hindi languages, all te .....

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