The court rejected the tax authorities` appeal and upheld the Court of Appeal`s decision on income tax that Maersk employees assigned to India are not taxable in India under the agreement, given that the employees` stay in India was less than 183 days and the remuneration was not paid by the stable establishment or fixed base of the non-resident employer. The Uttarakhand Supreme Court recently ruled that the country of residence was irrelevant under Article 16, paragraph 2 of the agreement on double tax evasion between India and Denmark as long as an employer is foreign to the territory. The Indian and Danish government intend to reach an agreement to avoid double taxation of income G.S.R. 316.– Considering that the attached agreement to avoid double taxation of income has been ratified between the Indian and Danish governments and that the ratification instruments covered by Article XX of that Convention have been exchanged: in order to avoid double taxation of income Denmark has concluded TDTs with a large number of countries. All tax treaties contain provisions relating to the exchange of tax information and specific EU rules apply. Double taxation can also be linked to inheritance tax. To remedy this situation, Denmark has entered into contracts in this regard with the other Scandinavian countries, Germany, Italy, Switzerland and the United States. The countries with which Denmark currently has DTTS and in which the contract contains a remuneration clause are the same: I would be grateful if you would confirm your agreement on the provisions of Article VI of the aforementioned agreement and, in this case, that this note and your reply be considered part of the agreement. Eu and European Economic Area (EEA) countries or countries with which Denmark has an agreement on social security (including international operations) include: agreement between the Government of the Russian Federation and the Government of the Republic of Albania to avoid double taxation of income and capital taxes The competent authorities exchange this information (which is available to them as part of a normal administrative procedure in their respective tax laws), to the extent necessary to implement the provisions of the agreement. All information thus exchanged is treated as secret and cannot be disclosed to anyone other than those involved in the taxation and collection of taxes that are the subject of this agreement. The competent authority of one of the territories where trade, trade, industrial or professional secrets or commercial procedures are disclosed to the authority of the other territory cannot murder any information. I would like to take this opportunity to renew to you, Mr MEP, the assurance of my greatest consideration. ff) The fact that a company domiciled in one of the territories has a subsidiary established in the other territory or which engages in an activity or commercial activity in that territory, by a stable establishment or by other means, constitutes a stable establishment of its parent company.

Income from real estate can only be taxed in the area where the property is located. To this end, all rents or royalties or other income from the operation of a mine, quarry or other extraction of natural resources are considered real estate income. . Capital gains from the sale, exchange or transfer of a property or personal property asset may only be taxed in the territory where the asset is located at the time of sale, exchange or transfer. . CONVENTION TO AVOID DOUBLE TAXATION AND THE PREVENTION OF TAX EVASION WITH ALBANIA THE GOVERNMENT OF THE REPUBLIC OF INDIA WITH REGARD TO INCOME AND CAPITAL TAXES . . . . Effective date: January 1, 1998 (Russia); April 1 and April 6, 1998 (United Kingdom) .