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Memorandum of Understanding to treaty between India and Denmark signed – Collection of taxes suspended during MAP

11 August 2008

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Treaty Development

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India-Denmark

India and Denmark have signed a Memorandum of Understanding (MOU) to suspend the collection of taxes during a Mutual Agreement Procedure (MAP) undertaken pursuant to Art. 25 of the India-Denmark tax treaty. The MOU will be applicable where a taxpayer is: -   a resident of Denmark; or -   an Indian resident entity in cases involving transfer pricing issues where the MAP has been invoked through Danish Competent Authority and admitted by the Indian Competent Authority. The effect of the MOU is that the furnishing of the bank guarantee should be treated as sufficient in order for the tax...