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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

As the moment of signing the Agreement this day concluded between the Government of Republic of India and the Government of the Republic of Mozambique for the Avoidance of Double Taxation and the prevention of fiscal evasion with respect of taxes on income, the undersigned have agreed upon the following provisions which shall be an integral part of the Agreement:

  • (1) For the purposes of Article 12 on Royalties it is understood that the term 'royalty' also includes payments made as remuneration for technical assistance which relates to the use of or the right to use the right or property referred to in paragraph (3) of Article 12 of this Agreement.
  • (2) For the purposes of Article 24 on Non-discrimination 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, nor as being in conflict with the provisions of paragraph (3) of Article 7.

IN WITNESS WHEREOF, the undersigned, duly authorized thereto, by their respective governments, have signed this Agreement.