Article - Agreements - Portuguese Republic - Article - Protocol At the moment of signing the Convention between the Republic of India and the Portuguese Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, the undersigned have agreed upon the following which shall be an integral part of the Convention. Ad Article 3 For the purposes of paragraph 3, the reference to the time of application of the Convention shall mean the time when the income which is the subject-matter of this Convention arises. Ad Article 3 and 23 For the purposes of paragraph 1(d), of Article 3 and Article 23, the expression tax shall not include any amount which is payable in respect of any default or omission in relation to the taxes to which the Convention applies or which represents a penalty imposed relating to those taxes. Ad Article 5 For the purposes of paragraph 2, a warehouse in relation to a person providing storage facilities for others will b

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