TMI BlogPROTOCOLX X X X Extracts X X X X X X X X Extracts X X X X ..... form an integral part of the Agreement: 1. Ad Article 5 It is understood that on the date of this Agreement none of the agreements for the avoidance of double taxation concluded by Lithuania provide for special provision deeming an insurance enterprise of a Contracting State to have a permanent establishment in the other Contracting State if it collects premiums or insures risks in the terri ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n respect of the head office expenses as referred to in paragraph 3 of Article 7 shall in no case be less than those allowable under the Indian Income-tax Act as on the date of entry into force of this Agreement. No deduction shall be allowed in respect of amounts paid or charged (otherwise than towards reimbursement of actual expenses) by the permanent establishment to the head office of the en ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t by the enterprise in international traffic, unless the containers are used solely within the other Contracting State; ( ii ) interest on funds directly connected with the operation of ships or aircraft in international traffic shall be regarded as profits from the operation of such ships or aircraft if they are integral to the carrying on of such business, and the provisions of Article 11 sha ..... X X X X Extracts X X X X X X X X Extracts X X X X
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