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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

PROTOCOL

At the signing of the Convention concluded today between the Government of the Republic of India and the Government of the Hashemite Kingdom of Jordan 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 provisions shall form an integral part of the said Convention:

ARTICLE 9

Associated Enterprises

(1) With reference to paragraph (2) of Article 9, it is understood that the provisions shall not apply in the case of fraud or willful default.

ARTICLE 17

Artists and Sportsmen

(2) With reference to paragraph (3) of Article 17, it is understood that the provisions shall apply in respect of income derived by an artiste from the activities performed in the other Contracting State under the cultural agreements concluded between the Governments of the Contracting States.

ARTICLE 24

Non-Discrimination

(3) With reference to paragraph (3) of Article 24, it is understood that this provision shall not be construed as preventing a Contracting State from charging the profits of a permanent establishment which a company of the other Contracting State has in the first-mentioned State at a rate of tax which is higher than that imposed on the profits of a similar company of the first-mentioned Contracting State.

IN WITNESS WHEREOF, the undersigned, being duly authorised thereto, have signed this Convention.

DONE in duplicate at New Delhi, this twentieth day of April 1999 in the Arabic, Hindi and English languages, all three texts being equally authentic. In case of divergence between the texts the English text shall be the operative one.

FOR THE GOVERNMENT OF THE HASHEMITE KINGDOM OF JORDAN:

HISHAM MUHAISEN

FOR THE GOVERNMENT OF REPUBLIC OF INDIA:

RAVIKANT