{"html": "<div class=\"lf-doc\"><p class=\"lf-p\">Ad Article 12, paragraph 3 : In applying Article 12, paragraph 3 of the Agreement payments constituting consideration for technical assistance or technical services shall not be considered to be payments for information concerning industrial, commercial or scientific experience, but shall be taxable in accordance with the provisions of Article 7 .3. Ad Article 14, paragraph 1 : An employment is exercised in a Contracting State when the activity in respect of which the salaries, wages and other similar remuneration are paid, is effectively carried on in that State.This means that the employee is physically present in that State for carrying on the activity there. 4. Ad Article 20, paragraph 3 and Article 21, paragraph 1, a) : For the application of paragraph 3 of Article 20 and of paragraph 1, a) of Article 21, income is taxed when it is effectively included in the taxable base by reference to which the tax is computed.Income is therefore not taxed when, being subject to the tax treatment normally applicable to such income, it is either not taxable or exempted from tax.</p>\n<p class=\"lf-p\">IN WITNESS WHEREOF, the undersigned, being duly authorised thereto by their respective Governments, have signed this Protocol.</p>\n<p class=\"lf-p\">Done in duplicate at Brussels, this 27th day of April 2006, in the English language.</p>\n<p class=\"lf-p\">PROTOCOL MODIFYING THE AGREEMENT BETWEEN THE KINGDOM OF BELGIUM AND THE REPUBLIC OF SEYCHELLES FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME SIGNED AT BRUSSELS ON 27 APRIL 2006 The Government of the Kingdom of Belgium and the Government of the Republic of Seychelles, Desiring to conclude a Protocol modifying the Agreement between the Kingdom of Belgium and the Republic of Seychelles for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, signed at Brussels on 27 April 2006 (hereinafter \"the Agreement\"), Have agreed as follows:</p>\n<h4 class=\"lf-art\" id=\"a-1-55\"><span class=\"lf-art-num\">Article 1</span></h4>\n<p class=\"lf-p\">The following paragraphs 5, 6 and 7 are inserted in Article 24 (Exchange of information) after paragraph 4: \" 5. In no case shall the provisions of paragraph 3 be construed to permit a Contracting State to decline to supply information requested by the other Contracting State because the information is held by a bank, other financial institution, nominee or person acting in an agency or a fiduciary capacity or because it relates to ownership interests in a person. 6. Banking records will be exchanged only upon request.If the request does not identify both a specific taxpayer and a specific bank or financial institution, the competent authority of the requested State may decline to obtain any information that it does not already possess. 7. The competent authorities of the Contracting States shall agree upon the mode of application of this Article.\" Article 2 1. Each Contracting State shall notify the other Contracting State of the completion of the procedures required by its laws for the bringing into force of this Protocol.2. This Protocol shall enter into force from the date on which the later of these notifications is received and its provisions shall have effect with respect to the taxes to which the Agreement has effect</p>\n<h4 class=\"lf-art\"><span class=\"lf-art-num\">Article 3</span><span class=\"lf-art-t\">This Protocol shall remain in force as long as the Agreement itself remains in force</span></h4>\n<p class=\"lf-p\">IN WITNESS WHEREOF the undersigned, being duly authorised thereto by their respective Governments, have signed this Protocol.</p>\n<p class=\"lf-p\">DONE in duplicate at Brussels, this 14 th day of July 2009, in the English language.</p></div>", "next": 0}