TMI BlogAvoidance of double taxationX X X X Extracts X X X X X X X X Extracts X X X X ..... he case of India as follows : (a) Where a resident of India derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in Denmark, India shall allow as a deduction from the tax on the income of that resident an amount equal to the income-tax paid in Denmark, whether directly or by deduction; and as a deduction from the tax on the capital of that resi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... x base but shall allow as a deduction from the income-tax or capital tax that part of the income-tax or capital tax which is attributable, as the case may be, to the income derived from or the capital owned in Denmark. 3. Double taxation shall be avoided in the case of Denmark as follows : (a) Subject to the provisions of sub-paragraph (c), where a resident of Denmark derives income or owns ca ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he tax base, but shall allow as a deduction from the income-tax or capital tax that part of the income-tax or capital tax which is attributable, as the case may be, to the income derived from or the capital owned in India; (d) For the purposes of the deduction referred to in sub-paragraph (a), the term "income-tax paid in India" shall be deemed to include any amount which would have been payable ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... not been modified thereafter or has been modified only in minor respects so as not to affect its general character; (e) For the purposes of deduction referred to in sub-paragraph (a), Indian tax on interest and royalties and fees for technical services shall in no case be considered as having been paid at a rate of less than, (i) in the case of interest (a) 10 per cent in the case of banks; ..... X X X X Extracts X X X X X X X X Extracts X X X X
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