At the signing the Agreement between the Republic of India and the Sultanate of Oman for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, both sides have agreed upon the following provision which shall be an integral part of the Agreement:
- "If an air transport enterprise of India with respect to profits referred to in Article 8 is charged to any tax of the kind referred to in Article 2 in one of the shareholding States of Gulf Air, the Contracting States shall reopen negotiations without delay with a view to arriving at an appropriate solution in respect of the application of Article 8 of the Agreement."
IN WITNESS WHEREOF, the undersigned, being duty authorised thereto, have signed this Protocol
DONE in duplicate at New Delhi, this 2nd day of April, one thousand nine hundred and ninety-seven in the Arabic, Hindi and English languages, all the texts being equally authentic. In case of divergent interpretation of the texts, the English text shall prevail.
FOR THE GOVERNMENT OF THE REPUBLIC OF INDIA:
FOR THE GOVERNMENT OF THE SULTANATE OF OMAN: