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Double Taxation Agreements With Brazil

2. The taxation of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State may not be levied in that other State at a price lower than that levied by enterprises of that other State carrying on the same activities. This provision should not be interpreted as requiring a State party to grant compensation, exemptions and tax reductions to residents of the other State party on account of civil status or family obligations it grants to its own residents. 5. There is a decision within and within the administration that each State Party may, at any time, not earlier than ten years after the entry into force of the Convention, attempt to verify some or all of its provisions by informing the competent authority of the other Contracting State in writing through the competent authority. The competent authorities shall, within six months, put in place appropriate procedures for carrying out that review. 3. Without prejudice to paragraph 1, compensation received by a worker established in a Contracting State for employment in the other Contracting State shall be taxable only in the first-mentioned Member State if this Convention does not affect the tax privileges of diplomatic agents or consular agents, in accordance with the general rules of international law or the provisions of special conventions. At the time of signature of the Agreement between the Republic of India and the Federative Republic of Brazil for the avoidance of double taxation and the prevention of fiscal evasion of income, the undersigned, duly coordinated, agreed on the following provisions which form an integral part of the Convention. Without prejudice to paragraphs 1 and 2, a person, with the exception of an independent representative to whom paragraph 5 applies, shall apply on behalf of an enterprise and shall have, in a Contracting State, the power to conclude contracts on behalf of the enterprise, that enterprise shall be deemed to be a permanent establishment in that State in respect of all activities carried on by that person for the enterprise: and exercise it habitually; unless the activities of that person are limited to those activities referred to in paragraph 3 which, if carried on through a permanent place of business, would not make that permanent establishment a permanent establishment in accordance with the provisions of this paragraph. . .

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