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    <title>2007 (8) TMI 36 - AUTHORITY FOR ADVANCE RULINGS</title>
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    <description>Employment income paid by an Indian employer to a non-resident employee for services rendered in Norway remained taxable in India, because Article 16(1) of the Indo-Norway DTAA allowed taxation in the State where the employment was exercised and Article 16(2) did not apply on the facts. The phrase &quot;may be taxed&quot; was treated as permitting taxation under domestic law, so Indian taxation was not excluded merely because the salary was paid in India or the employee was non-resident. No treaty relief was available, since the applicant produced no evidence of actual Norwegian taxation, tax payment, exemption, or credit entitlement.</description>
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      <title>2007 (8) TMI 36 - AUTHORITY FOR ADVANCE RULINGS</title>
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      <description>Employment income paid by an Indian employer to a non-resident employee for services rendered in Norway remained taxable in India, because Article 16(1) of the Indo-Norway DTAA allowed taxation in the State where the employment was exercised and Article 16(2) did not apply on the facts. The phrase &quot;may be taxed&quot; was treated as permitting taxation under domestic law, so Indian taxation was not excluded merely because the salary was paid in India or the employee was non-resident. No treaty relief was available, since the applicant produced no evidence of actual Norwegian taxation, tax payment, exemption, or credit entitlement.</description>
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