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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

On formalization, this SAARC Limited Multilateral Agreement on avoidance of double taxation and mutual administrative assistance in tax matters shall be applicable only in the Member States where an adequate Direct Tax Structure is in place. Further, in case of a Member State where such a structure is not in place, this Agreement shall become effective from the date on which such a Member State introduces a proper Direct Tax Structure and notifies the SAARC Secretariat to this effect.

Further that in the event of a conflict between the provisions of this Limited Multilateral Agreement and that of any bilateral Double Taxation Avoidance Agreement between the Member States, the provisions of the Agreement signed or amended at a later date shall prevail.

DONE at Dhaka, Bangladesh, on this thirteenth day of November 2005, in nine originals in the English language, all texts being equally authentic.

FOR THE PEOPLE'S REPUBLIC OF BANGLADESH:

M. MORSHED KHAN

FOR THE KINGDOM OF BHUTAN:

KHANDU WANGCHUK

FOR THE REPUBLIC OF INDIA:

E. AHAMED

FOR THE REPUBLIC OF MALDIVES:

AHMED SHAHEED

FOR THE KINGDOM OF NEPAL:

RAMESH NATH PANDEY

FOR THE ISLAMIC REPUBLIC OF PAKISTAN:

KHURSHID M. KASURI

FOR THE DEMOCRATIC SOCIALIST REPUBLIC OF SRI LANKA:

ANURA BANDARANAIKE