2. The Agreement also applies to all identical or essentially similar taxes levied by one of the contracting parties after the date of signing this agreement, in addition to the taxes covered in paragraph 1 or in your place. The competent authorities of the contracting states inform each other of any substantial changes to their respective tax laws. This paragraph does not affect the corporation`s taxation on the profits on which the dividends are paid. 5. As used in this section, the term „dividends“ refers to income from shares or other non-profit rights, as well as income from other rights of corporations treated as proceeds of shares by the tax laws of the contracting state whose distribution is distributed, and anything other than interests covered by section 12, which is considered a dividend or distribution under the Act. A. For the purpose of determining the profits of a stable establishment, the deduction may be made at second-place expenses, including administrative expenses incurred in the contracting state where the establishment is located or in another location, in accordance with the provisions and subject to the limitations of the tax legislation of that contracting state. Where the law of the State party in which the establishment is established imposes a limitation on the level of authorized administrative expenses of the executive and general administrative expenses and the restriction is relaxed or repealed by a convention, agreement or protocol signed after 1 January 1990 between that State party and a third member state of the OECD, and that limitation is applied by a convention signed after 1 January 1990 , the agreement or protocol between that contracting state and a third oecd member state will be relaxed or repealed. The competent authority of that contracting State communicates to the competent authority of the other State party, as soon as this Convention, Convention or Protocol comes into force, the provisions of the corresponding paragraph of the convention, agreement or protocol with that third country, and, at the request of the competent authority of the other State party, the provisions of this paragraph apply in accordance with this Convention from that entry into force.

(d) if he is a national of the two contracting states or of one of those contracting states, the competent authorities of the contracting states resolve the matter by mutual agreement. Income Tax Act,1961:Communication of Section 90:Convention between the Government of the Republic of India and the Government of the French Republic on the Prevention of Double Taxation and Prevention of Tax Fraud with respect to Income and Capital Taxes d.d)the term „person“ refers to a natural person , a corporation and any other entity considered a taxable entity under the tax legislation in force in the relevant contracting states. Specific provisions apply to border workers in the following double taxation agreements: 1.