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Article 31 - TERMINATION - MozambiqueExtract Article 31 TERMINATION This Agreement shall remain in force indefinitely until terminated by one of the Contracting States. Either Contracting State may terminate the Agreement, through diplomatic channels, by giving to the other Contracting State notice of termination at least six months before the end of any calendar year beginning after the expiration of five years from the date of entry into force of the Agreement. In such event, the Agreement shall cease to have effect: ( a ) In India, in respect of income derived in any fiscal year on or after the first day of April next following the calendar year in which the notice is given; ( b ) In Mozambique, in respect of income derived in any fiscal year on or after the first day of January next following the calendar year in which the notice is given. IN WITNESS WHEREOF the undersigned, duly authorized thereto, by their respective Governments, have signed this Agreement. DONE in duplicate at New Delhi this 30th day of September 2010 each in the Hindi, Portuguese and English languages, all texts being equally authentic. In case of divergence of interpretation, the English text shall prevail. PROTOCOL As the moment of signing the Agreement this day concluded between the Government of Republic of India and the Government of the Republic of Mozambique for the Avoidance of Double Taxation and the prevention of fiscal evasion with respect of taxes on income, the undersigned have agreed upon the following provisions which shall be an integral part of the Agreement: 1. For the purposes of Article 12 on Royalties it is understood that the term 'royalty' also includes payments made as remuneration for technical assistance which relates to the use of or the right to use the right or property referred to in paragraph 3 of Article 12 of this Agreement. 2. For the purposes of Article 24 on Non-discrimination it is understood that this provision shall not be construed as preventing a Contracting State from charging the profits of a permanent establishment which a company of the other Contracting State has in the first mentioned State at a rate of tax which is higher than that imposed on the profits of a similar company of the first mentioned Contracting State, nor as being in conflict with the provisions of paragraph 3 of Article 7. IN WITNESS WHEREOF the undersigned, duly authorized thereto, by their respective governments, have signed this Agreement.
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