Ad Article. 24 In the case of the Kingdom of Saudi Arabia, the methods for elimination of double taxation will not prejudice the provisions of the Zakat collection regime as regards the Saudi nationals. IN WITNESS WHEREOF the undersigned, duly authorised thereto, have signed this Protocol. DONE in Beijing on the 23rd day of January, 2006 in duplicate, each in the Chinese, Arabic and English languages, all texts being equally authentic. In case of divergence of interpretation, the English text shall prevail. For the Government of For the Government of The People’s Republic of China The Kingdom of Saudi Arabia Xx. Xxx Xuren Xx. Xxxxxxx Bin Xxxxxxxxx Xx-Xxxxx Commissioner Minister of Finance of the State Administration of Taxation
Ad Article. 5 For the purposes of sub-paragraphs e) and f) of paragraph 4 it is understood that the mere facilitation of the conclusion (including the mere signing) of contracts, such as contracts concerning loans or the delivery of goods or merchandise, shall be considered as an activity of a preparatory or auxiliary character.
Ad Article. 4 An individual living aboard a ship without any real domicile in either of the Contracting States shall be deemed to be a resident of the Contracting State in which the ship has its home harbour.
Ad Article. 2 The Contracting Parties shall within the framework of their national legislation give sympathetic consideration to applications for the entry and sojourn of persons of either Contracting Party who wish to enter the territory of the other Contracting Party in connection with an investment; the same shall apply to employed persons of either Contracting Party who in connection with an investment wish to enter the territory of the other Contracting Party and sojourn there to take up employment. Applications for work permits shall also be given sympathetic consideration.
Ad Article. 2 The Treaty shall also apply in the areas of the exclusive economic zone and the continental shelf to the extent that international law permits the exercise of sovereign rights or powers in these areas by the respective Contracting Party.
Ad Article. 22 The exemption provided in sub-paragraph (b) of paragraph 1 of Article 22 shall not apply if it was the main purpose of any person concerned with the creation or assignment of the shares or other rights in respect of which the income is paid to take advantage of this provision by means of that creation or assignment. In that case, subparagraphs 10.2.a) ii) or 10.4 a) ii) shall apply. The provisions of sub-paragraph (d) of paragraph 1 of Article 22 shall cease to have effect after 10 years since the entry into force of this Agreement. After this period, the Competent Authorities will jointly consider an extension of the provisions hereinbefore mentioned.
Ad Article. 23 For the purposes of sub-paragraph (a) of paragraph 2 and sub- paragraph (b) of paragraph 3 of Article 23, it is understood that if, after the date of signature of the Agreement, the law of a Contracting State is amended with regard to the allowance of tax credit or the reduction of tax, the competent authority of that State shall inform the competent authority of the other Contracting State of the amendments so made and, if the competent authority of that other Contracting State so requests, the competent authorities of both States shall consult each other with a view to amend the Agreement, if necessary. In witness whereof the undersigned, being duly authorised thereto, have signed the present Protocol. Done in duplicate at Brussels, this 26th day of April, one thousand nine hundred and ninety three, in the Hindi, English, French and Dutch languages, all four texts being equally authentic. In case of divergence of interpretation, the English text shall prevail. FOR THE GOVERNMENT OF THE REPUBLIC OF INDIA: ... FOR THE GOVERNMENT OF THE KINGDOM OF BELGIUM
Ad Article. 23 The provisions of paragraph 3 shall apply to the extent that the contracts regarding transference of technology are registered or authorized according to the requirements of the domestic law of the Argentine Republic.
Ad Article. 24 The competent authorities of the Contracting States may also agree, with respect to any agreement reached as a result of a mutual agreement procedure as meant in Article 24, if necessary contrary to their respective national legislation, that the State in which there is an additional tax charge as a result of the aforementioned agreement shall not impose any increases, surcharges, interest and costs with respect to this additional tax charge, if the other State in which there is a corresponding reduction of tax as a result of the agreement refrains from the payment of any interest due with respect to such a reduction of tax.
Ad Article. 2 It is understood that the Convention shall not apply to taxes withheld at source on income by chance covered by Article 6 of the Swiss Anticipatory Tax Law.
