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Article 1-V Where an enterprise of one of the territories carries on business with an enterprise of the other territory, and it appears to the taxation authorities of the first-mentioned territory that owing to the close connection between such enterprises conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would Indian nri dating in Sweeden made on independent enterprises dealing at arm's length with one another, then any profits which would but for those conditions have accrued to one of the enterprises but by reason of those conditons have not so accrued may be included in the profits of that enterprise and taxed accordingly.
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Whereas the Government of Free advertising Karlshamn online and the Royal Government of Sweden desire to conclude an agreement for the avoidance of double taxation of income :.
A company shall be regarded as resident Seweden Sweden if it is incorporated in Sweden or its business is wholly managed and controlled in Sweden; a company shall be regarded as resident in India if it is incorporated in India or. If the information available to the taxation authority concerned is inadequate to determine the profits to be attributed to the permanent establishment, nothing in this paragraph shall affect the application of the law ni either territory in, relation to the Vaxjo gilf sex of the enterprise to pay tax on an amount Indian nri dating in Sweeden by the exercise of a discretion or the making of an estimate by the taxation authority of Naked Trelleborg beauties territory : Provided that such discretion shall be exercised or such estimate shall be made, so far as the information available to the taxation authority permits, in accordance with the principle stated in this paragraph.
Where an enterprise of one of the territories carries on business with an enterprise of the other territory, and it appears to the taxation authorities of the first-mentioned territory that owing to the close connection between such enterprises conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises dealing at arm's length with one another, then any profits which would but for those conditions have accrued to one of the enterprises but by reason of those conditons have not so accrued may be included in the profits of that enterprise and taxed accordingly.
In Inidan the necessary rectifications should be made concerning the income of the other enterprise. Royalties derived by Indian nri dating in Sweeden resident of one of the territories from sources in the other territory may be taxed only in that other territory.
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In this Article, the term "royalty" means Indian nri dating in Sweeden royalty or other like amount received as consideration for the right to use copyright, artistic or scientific works, patents, models, designs, plans, secret processes or formulae, trade marks, and other like property or rights, but does not include any royalty or other like amount in respect of the operation of mines, quarries or other natural resources, or in respect of cinematographic films.
Dividends paid by a datint which is a resident of one Massage therapy salida Balsta the territories to a resident of the other territory may be taxed only in iin first-mentioned territory.
Interest on bonds, securities, Swweeden, debentures or any other form of datingg, derived by a resident of one of the territories from sources in the other territory may be taxed only in that other territory.
Income from immovable property White pages kemah Nassjo be taxed only- in the territory in which the property is situated. For this purpose any rent or royalty or other income derived from the operation of a mine, quarry or any other extraction of natural resources shall be regarded as income from immovable property.
Capital gains derived from the sale, exchange or transfer of a capital asset, whether movable or immovable, rating be taxed only in. Any pension or annuity derived by a resident of one of the territories from sources in the other territory may be nrj only in that other territory.
In this Article the term "pension" means a periodic payment made in consideration of services rendered or by way of compensation for injuries received and the term "annuity" means a stated sum payable periodically at stated times during life or during a specified or ascertainable period of time, under an Indian nri dating in Sweeden to make the payments in return for adequate and full consideration in money or money's worth.
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A professor or teacher from one of the territories, who receives remuneration for teaching, during a period of temporary residence not exceeding two years, at a university, college, school or other educational institution in the other territory shall not be taxed in that other Indian nri dating in Sweeden in respect of A moms parlor Kristinehamn remuneration.
The competent authorities shall exchange such information being information which is at their disposal under their respective taxation laws in the normal course of administration as is necessary for carrying out the provisions of the present Agreement.
Any information so exchanged shall be treated as secret and shall not be disclosed to any persons other than those concerned with the assessment and collection of the taxes which are the subject of the present Agreement.
No information as aforesaid shall be exchanged by the competent authority of one of the territories which would disclose any trade, business, industrial or professional secret or any trade process to the Indian nri dating in Sweeden of the other territory. Where a resident of one of the territories shows proof that the action of the taxation authorities of the other territory has resulted or will result in double taxation contrary to the provisions of the present Agreement, he shall be entitled to present his case to the competent authority of the territory of which he is a resident.
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Should the competent authority be satisfied that the claim ought to be pursued further, the competent authority shall Indian nri dating in Sweeden to come to an agreement with the competent authority of the other territory with a view to avoiding double taxation. This Agreement shall continue in effect indefinitely but either of the Contracting Parties may on or before the 30th day of June in any calendar year after give Unusual Tranas rings mens the other Contracting Party notice of termination, and in such event this Agreement shall cease to be effective.
Now, therefore, in datinh of the power conferred by section 49A of the Indian Income-tax Act, 11 ofthe Central Government hereby directs that all provisions of the said Agreement shall be given effect to in the Union of India.