1. This agreement does not affect the tax privileges of diplomatic or consular officials under the general rules of international law or the provisions of specific agreements. 2. This agreement does not affect the taxation of a company established in Belgium in the event of a share buyback or asset allocation. 6. This article refers to the concept of “taxation” of any kind, as defined in this agreement. 1. For the purposes of this agreement, the term residing in a contracting state refers to any person established in that state under that state`s law for the purposes of taxation. In order to conclude an agreement to avoid double taxation and to prevent income tax evasion in relation to income tax, the agreement between the Government of the Russian Federation and the Government of the Republic of Albania to avoid double taxation on income and capital taxes [This agreement] 1 does not affect the taxation of its residents by a contracting state. , with the exception of the benefits granted under Article 9 of this agreement, in the form amended by Article 17, paragraph 1, of the MLI and Articles 19, 20, 21, 23, 24, 25 and 28 of this agreement.
India and Belgium signed a protocol on Thursday amending the existing agreement on the prevention of double taxation (DBA) between the two countries. 3. (a) In the case of determining the profits of a stable establishment, the costs associated with the establishment`s activity, including administrative expenses incurred for the executive and management overhead, whether in the state where the establishment is located or in any other location, are admitted within the limits of the state`s tax legislation. Provided that the law of the state in which the institution is located imposes a limit on the level of administrative expenses authorized for the executive and general administrative costs and that this restriction is relaxed or repealed by an agreement or agreement between that state and a third member state of the OECD that will come into force after this agreement comes into force. , the competent authority of that State notifies the competent authority of the other State party, as soon as this Convention or Convention comes into force, of the provisions of the corresponding paragraph of the paragraph corresponding with that third country, and if the competent authority of the other State party requests it, the provisions of this paragraph are amended by a protocol to take account of these conditions.