TMI BlogTerminationX X X X Extracts X X X X X X X X Extracts X X X X ..... ising in any fiscal year beginning on or after the first day of January next following the calendar year in which the notice of termination is given. In witness whereof the undersigned, being duly authorised thereto, have signed this Agreement. Done in two originals at New Delhi this 3rd day of November, 2003 in Hindi, the Hungarian and English languages, all three texts being equally authentic. In case of divergence between the texts the English text shall prevail. PROTOCOL At the moment of signing the Convention between the Republic of Hungary and the Republic of India for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, the undersigned have agreed that the following provisi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ax Act, 1961, as effective on the date of the signing of this Convention. With reference to Article 10 When the company paying the dividends is a resident of India the tax on distributed profits shall be deemed to the taxes in the hands of the shareholders and it shall not exceed 10 per cent of the gross amount of dividend. With reference to Articles 10, 11 and 12 In respect of Articles 10 (Dividends), 11 (Interest) and 12 (Royalties and fees for technical services), if under any Convention, Agreement or Protocol between India and a third State which is a member of the OECD, India limits its taxation at source on dividends, interest, royalties or fees for technical services to a rate lower or a scope more restricted than the rat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ngary may subject to tax in Hungary in addition to the tax on profits attributable to that permanent establishment. However such additional tax may not exceed 10 per cent of the profits of the enterprise attributable to the permanent establishment after deducting therefrom the tax on profits chargeable on the profits of a company which is a national of Hungary and imposed on the profits of the enterprise attributable to the permanent establishment by Hungary. IN WITNESS whereof the undersigned, being duly authorised thereto, have signed this Agreement. DONE in two originals at New Delhi this 3rd day of November, 2003 in Hindi, the Hungarian and English languages, all three texts being equally authentic. In case of divergence between t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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