TMI BlogTerminationX X X X Extracts X X X X X X X X Extracts X X X X ..... years from the date of entry into force of the Convention. In such event, the Convention shall cease to have effect: (a) in India, in respect of income arising 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 Ireland: (i) in respect of income tax and capital gains tax, for any year of assessment beginning on or afte ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... FOR THE GOVERNMENT OF IRELAND THE REPUBLIC OF INDIA PROTOCOL At the signing of the Convention between the Government of the Republic of India and Government of Ireland for Avoidance of Double Taxation and for the Prevention of Fiscal Evasion with respect to taxes on income and capital gains, the undersigned have agreed that the following shall form an integral part of the Co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in accordance with the laws of a Contracting State, profits are attributed to a permanent establishment of an enterprise carrying on insurance business, on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment; the method of apportionme ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vention, the laws of Ireland in this respect change and Ireland enters into an arrangement with another country to permit such assistance in collection, then Ireland shall inform the Indian competent authority and, if requested by such authority, shall immediately enter into negotiations for the purpose of incorporating provisions with regard to collection assistance in this Convention. IN WITNE ..... X X X X Extracts X X X X X X X X Extracts X X X X
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