Convention between the Republic of India and the Kingdom of Denmark for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital - 0853(E) - Income Tax Act, 1961
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Tax treaty allocation of taxing rights and withholding ceilings between India and Denmark to prevent double taxation and fiscal evasion. Convention allocates taxing rights between India and Denmark for residents and specified taxes on income and capital, defines key terms including resident and permanent establishment, provides tie breaker rules for dual residence and place of effective management, and sets withholding ceilings and source/residence rules for dividends, interest, royalties, business profits and capital gains. It prescribes arm's length profit attribution to permanent establishments, non discrimination protections, methods for elimination of double taxation by credit, and administrative cooperation through mutual agreement, information exchange and assistance in collection, with Protocols extending coverage and fixing procedural thresholds.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Tax treaty allocation of taxing rights and withholding ceilings between India and Denmark to prevent double taxation and fiscal evasion.
Convention allocates taxing rights between India and Denmark for residents and specified taxes on income and capital, defines key terms including resident and permanent establishment, provides tie breaker rules for dual residence and place of effective management, and sets withholding ceilings and source/residence rules for dividends, interest, royalties, business profits and capital gains. It prescribes arm's length profit attribution to permanent establishments, non discrimination protections, methods for elimination of double taxation by credit, and administrative cooperation through mutual agreement, information exchange and assistance in collection, with Protocols extending coverage and fixing procedural thresholds.
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