TMI BlogPROTOCOLX X X X Extracts X X X X X X X X Extracts X X X X ..... hich shall be an integral part of the Agreement: 1. With reference to paragraph 3 of Article 5, its understood that, for the purposes of computing the time limits referred to in that paragraph, such activities performed by an enterprise related to another enterprise within the meaning of Article 9, shall be added to the period during which activities are performed by the enterprise, provided ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fees for technical services includes payments as consideration for provision of services of technical or other personnel in accordance with the provisions of section 9 of the Income-tax Act, 1961 . 4. It is understood that if the domestic law of a Contracting State is more beneficial to a resident of the other Contracting State than the provisions of this Agreement, then the provisions ..... X X X X Extracts X X X X X X X X Extracts X X X X
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