Protocol - Protocol - Czechoslovak [Slovak Republic]

PROTOCOL At the time of signing the Agreement for the Avoidance of Double Taxation and the prevention of fiscal evasion with respect to taxes on income, this day concluded between the Government of India and the Government of the Czechoslovak Socialist Republic, the undersigned Plenipotentiaries have agreed that the following provisions shall form an integral part of the Agreement. I. ARTICLE 5 (PERMANENT ESTABLISHMENT) (i) The term assembly project as used in clause (g) of paragraph 2 includes installation of equipment. (ii) The provisions of clauses (a) and (b) of paragraph 3 shall apply, mutatis mutandis, to a case where the use of facilities or maintenance of stock of goods or merchandise is, in addition to storage or display, for the purpose of delivery of spare parts, and components by way of replacement, during the period of the respective contract, from stock of goods stored in the Contracting State. II. ARTICLE 8 (AIR TRANSPORT) Notwithstanding anything contained in Article 28, the provisions of Article 8 relating to Air Transport shall be applicable from 1st January, 1961, and the tax paid, if any, will be refunded on application being made within twelve months of the entry into force of the Agreement. Dated 14th April, 1986 No. PRA/204/2/86.Com, The Embassy of India presents its compliments to the Federal Ministry of Foreign Affairs, Government of the Czechoslovak Socialist Republic and with reference to Article 28 of the Agreement between the Government of India and the Government of the Czechoslovak Socialist Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, signed at New Delhi on the 27th January, 1986, has the honour to state that the Government of India have complied with the requirements necessary for bringing into force of the Agreement. 2. Accordingly, the Embassy has the honour further to state that the aforesaid Agreement will enter into force with a similar note confirming that the Government of the Czechoslovak Socialist Republic have also complied with the requirements of Article 28 of the said Agreement. 3. The Embassy of India avails itself of the opportunity to renew to the Federal Ministry of Foreign Affairs the assurances of its highest consideration. seal Embassy of India Pargue Federal Ministry of Foreign Affairs of the Czechoslovak Socialist Republic, Prague No. 1042/87. The Embassy of the Czechoslovak Socialist Republic in India presents its compliments to the Ministry of External Affairs, Government of India, and has the honour to notify that the Agreement between the Government of the Czechoslovak Socialist Republic and the Government of the Republic of India for the Avoidance of Double Taxation and the prevention of fiscal evasion with respect to taxes on income, signed in New Delhi on 27th January, 1986, has been, as required in Article 28 of the said Agreement, duly ratified in accordance with the Czechoslovak legal regulations. The Embassy of the Czechoslovak Socialist Republic avails itself of this opportunity to renew to the Ministry of External Affairs the assurances of its highest consideration. New Delhi , March 3, 1987 (seal) Embassy of the Czechoslovak Socialist Republic The Ministry of External Affairs, Government of India, New Delhi [No. 7311 (F. No. 11|22|G6-F.T.D.) J V. U. ERADI, Jt. Secy