With reference to Articles. 8 and 22, the provisions of Articles 8 and 22 of the Agreement shall apply to any item of income derived from the Federal Republic of Germany, or to any item of capital situated within the Federal Republic of Germany owned, by a company or a body of persons treated as an entity for tax purposes which is a resident of Singapore more than 50 per cent of the capital of which is owned directly or indirectly by persons who are not residents of Singapore, only if such company or body of persons proves that the Singapore tax appropriate to the income is equal to the Singapore tax which would have been appropriate to such income if the Singapore tax were computed without regard to any provision identical or similar to the provisions of section 13A of the Singapore Income Tax Ordinance as inserted by the Income Tax (Amendment) Act, 1969.
With reference to Articles. 10 and 11 If after the entry into force of this Agreement, Viet Nam has signed an Agreement for the avoidance of double taxation with a third State which is a member of the European Union or the Organisation for Economic Co-operation and Development, and that Agreement contains lower withholding tax rates (including zero rates) and lower participating percentages than those provided for under this Agreement, these rates and percentages will automatically replace the rates and percentages of this Agreement, from the date of entry into force of the Agreement between Viet Nam and that third State.
With reference to Articles. 8 and 9 if at any time after the date of signature of the Convention the Philippines agrees to a lower or nil rate of tax with a third State the Government of the Republic of the Philippines shall without undue delay inform the Government of India through diplomatic channels and the two Governments will undertake to review these Articles with a view to providing such lower or nil rate to profits of the same kind derived under similar circumstances by enterprises of both Contracting States.
