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Protocol - PROTOCOL - FijiExtract PROTOCOL At the moment of signing the Agreement this day concluded between the Government of the Republic of India and the Government of the Republic of Fiji for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, the undersigned have agreed upon the following provisions which shall be an integral part of the Agreement. 1. With reference to Article 2, it is understood that `land sales tax' in Fiji means tax on sale proceeds on land which were held for continuous period of 12 years; 2. It is understood that the term may be taxed in the other State wherever appearing in the Agreement should not be construed as preventing the country of residence from taxing the income. IN WITNESS WHEREOF the undersigned, duly authorized thereto, have signed this Protocol. DONE in duplicate at New Delhi this thirtieth day of January 2014, each in the Hindi and English languages, both texts being equally authentic. In case of divergence of interpretation, the English text shall prevail. For the Government of the of India: For the Government of the Republic of Fiji: (P. CHIDAMBARAM) MINISTER OF FINANCE (AIYAZ SAYED-KHAIYUM) ATTORNEY GENERAL AND MINISTER OF INDUSTRY AND TRADE
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