1. This agreement will enter into force on the date on which the last of these matters would have been made in Fiji and New Zealand, to the extent necessary to give the agreement the force of matter in force in Fiji and New Zealand, as its provisions relate respectively to the Fijian tax and the New Zealand tax. , and therefore has an effect, with a view to concluding a second protocol to the agreement reached between the States Parties to avoid double taxation. and the prevention of income tax evasion, signed on October 27, 1976 in Wellington (`convention`), with the aim of concluding an agreement to avoid double taxation and prevent tax evasion with respect to income, It is stated that the provisions contained in the Schedules Agreement 1 , 2 and 3 , since these are agreements that have been made with the Fijian government to allow double taxation exemption with respect to income and income tax under the Income And Income Tax Act 1954 (including property and normal tax, non-resident dividend tax). , interest payments tax and dividend tax) that are levied under Fijian law. , with respect to income tax and surtax tax imposed under this Act, notwithstanding all the provisions of this Act or any other decree, to be effective in accordance with the content of the agreement. (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. 1. Where a subject finds that the action brought by the competent authority of a contracting state has resulted in or is likely to result in double taxation contrary to the provisions of this convention, he is entitled to submit the facts to the competent authority of the contracting state of which he resides and, if the applicant`s claim is considered worthy. , the competent authority of that State party strives to reach an agreement with the competent authority of the other State party with regard to the prevention of double taxation in question. 4.
In the application of the provisions of this Convention by a contracting state, any clause that is not otherwise defined has the importance it has, under the legislation of that contracting state, with respect to the taxes to which this agreement applies under Article 2. No unnecessary reference words (for example. B “this section” and “this Act” (4) If the application of the tax limit in paragraph 1 of this section is not excluded by the previous provisions of this section, but because of a special relationship between the person who pays the interest and the person who is the economic beneficiary of the interest, or between the two and another person , the amount of interest paid exceeds the amount of interest paid the limit on the amount of tax provided in paragraph 1 of this section applies only to the last amount indicated. In this case, the excess portion of the payments remains taxable in accordance with the law of each State party.