In both cases, conditions are established or imposed between the two undertakings in their commercial or financial relations which are different from those which would be obtained between independent undertakings, so that profits which would have been made to one of the undertakings without those conditions but which did not arise as a result of those conditions may be included in the profits of that undertaking and taxed accordingly. 1. The determination and taxation of income in the respective territories shall continue to be governed by the laws in force in both territories, except as otherwise expressly provided in this Agreement. 1. Where a resident proves that the act of the tax authorities of the other territory has led or will result in double taxation contrary to the provisions of this Agreement, he shall have the right to submit his observations to the competent authority of the territory in which he is established. Where its application is deemed worthy of examination, the competent authority to which the application is submitted shall endeavour to reach an agreement with the competent authority of the other territory in order to avoid double taxation. 2. The competent authorities of the Contracting Parties may also conclude an agreement for the avoidance of double taxation in cases not otherwise provided for in this Agreement and in cases where the interpretation or application of this Agreement raises difficulties or doubts. In order to avoid double taxation of income, Denmark has concluded DVB-TS with a large number of countries. All tax treaties contain rules for the exchange of tax information, and specific EU rules also apply.
Double taxation can also occur in the context of inheritance tax. To remedy this situation, Denmark has concluded contracts in this regard with the other Scandinavian countries, Germany, Italy, Switzerland and the United States. The countries with which Denmark currently has DVB-T and in which the contract contains a remuneration clause are as follows: The competent authorities exchange the information (i.e. the information they have under their respective tax legislation in the context of normal administration) necessary for the implementation of the provisions of this Agreement. The information thus exchanged shall be kept secret and shall not be disclosed to persons other than persons involved in the determination and collection of taxes covered by this Agreement. The competent authority of one of the territories that discloses commercial, commercial, industrial or professional secrets or commercial procedures to the authority of the other territory shall not exchange the above information. (ee) a broker with truly independent status acting merely as an intermediary between an undertaking situated in one of the territories and a potential client in the other territory shall not be considered to be a permanent establishment in that other territory if those activities are not related to the acquisition of orders within the meaning of point (d)(3); above. The Agreement between the Government of India and the Royal Government of Denmark on the Prevention of Double Taxation of Income, signed today, I have the honour to inform you, on behalf of the Government of India, that the provisions of Article VI of the said Agreement are without prejudice to the application of the provisions of Sections 44A and 44B of the Indian Income Tax Act — 1922 with respect to the valuation of the profits of occasional vessels and vessels steam from tramps, provided that in the event of an adjustment under section 44C of the Indian Income Tax Act, 1922, the provisions of Article VI of the Agreement apply to occasional ships or tramp steamboats.
I should be grateful if you would understand above the provisions of article VI of the said Agreement and to ensure that, in that case, this note and your response thereto are considered to be part of the Agreement. The Governments of India and Denmark intend to conclude an Agreement for the Avoidance of Double Taxation of Income G.S.R. 316.-The attached Convention for the Avoidance of Double Taxation of Income between the Governments of India and Denmark has been ratified and the instruments of ratification have been exchanged in accordance with Article XX of the said Agreement. EU/European Economic Area (EEA) countries or countries with which Denmark has a social security agreement (including missions abroad) include: (1) Income from the operation of aircraft by one company in one of the territories is not taxed in the other territory unless the aircraft is operated wholly or mainly between sites in that other territory. . . . IN WITNESS WHEREOF, the undersigned, being duly authorized thereto, have signed this Agreement and affixed it to their seals. 4. Paragraphs 1 and 2 of this Article shall also apply to remuneration other than pensions paid by the Reserve Bank of India, the public railway authorities and the Postal Administration of India, as well as by the National Bank of Denmark, the State Railways and the Postal Administration of Denmark.
3. Paragraphs 1 and 2 shall not apply to profits from coastal traffic. . 2. A natural person resident in India shall not be taxed in Denmark on the profits or remuneration referred to in paragraph 1 if:. 3. Paragraphs 1 and 2 of this Article shall not apply to payments for services related to a trade or activity carried out for profit by any of the Parties or their political subdivisions. 2. Subject to Article VI, income from sources in Denmark which is taxed in Denmark under Danish law and in accordance with this Agreement, either directly or by deduction, shall not be subject to Indian tax. . (b) the services are provided to or on behalf of an enterprise established in India; (1) `competent authority` means, in the case of India, the central government within the Ministry of Finance, the Ministry of Finance or its authorised representative and, in the case of Denmark, the Minister of Finance or his authorised representative.
. AGREEMENT BETWEEN THE GOVERNMENTS OF INDIA AND DENMARK ON THE PREVENTION OF DOUBLE TAXATION OF INCOME. The note and this reply shall be deemed to form part of the Agreement. (bb) An enterprise situated in one of the territories shall be deemed to have a permanent establishment in the other territory if it carries out a construction, installation or assembly project or similar in that other area. Unused credits are non-refundable and cannot be transmitted or transmitted. (a) `Denmark` means the Kingdom of Denmark, with the exception of the Faroe Islands and Greenland; Fees levied by a resident of sources in the other territory may be taxed only in that other territory. . (a bis) “Business fixed” means a place of management, a branch, an office, a factory, a workshop, a warehouse and a mine, a quarry or any other place of extraction of natural resources. (b) in Denmark, national and municipal income taxes, hereinafter referred to as `Danish tax`. .