【法规名称】
【颁布时间】 2005-08-30
【效力属性】 有效
【法规编号】 34666 什么是编号？
【正 文】
第6页 AGREEMENT BETWEEN THE TAIPEI REPRESENTATIVE OFFICE IN DENMARK AND THE DANISH TRADE ORGANISATIONS’ TAIPEI OFFICE FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME
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[接上页] 4.Gains derived by a resident of a territory from the alienationof shares deriving more than 50 per cent of their value direc-tly or indirectly from immovable property situated in the oth-er territory may be taxed in that other territory. 5.Gains from the alienation of any property other than that ref-erred to in paragraphs 1, 2, 3 and 4 shall be taxable only inthe territory of which the alienator is a resident. 6.Where enterprises from different jurisdictions have agreed tooperate ships or aircraft in international traffic through abusiness consortium, the provisions of paragraph 3 shall applyonly to such proportion of the capital gains as corresponds tothe participation held in that consortium by an enterprise ofa territory. Article 14 Income from Employment 1.Subject to the provisions of Articles 15, 17 and 18, salaries,wages and other similar remuneration derived by a resident ofa territory in respect of an employment shall be taxable onlyin that territory unless the employment is exercised in theother territory.If the employment is so exercised, such rem-uneration as is derived therefrom may be taxed in that otherterritory. 2.Notwithstanding the provisions of paragraph l, remunerationderived by a resident of a territory in respect of an employm-ent exercised in the other territory shall be taxable only inthe first-mentioned territory if: a) the recipient is present in the other territory for a periodor periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the fiscal yearconcerned, and b) the remuneration is paid by, or on behalf of, an employerwho is a resident of the first-mentioned territory, and c) the remuneration is not borne by a permanent establishmentwhich the employer has in the other territory. 3.Notwithstanding the preceding provisions of this Article, rem-uneration derived in respect of an employment exercised aboarda ship or aircraft operated in international traffic by an en-terprise of a territory, may be taxed in that territory. Article 15 Directors' Fees Directors' fees and other similar payments derived by a residentof a territory in his capacity as a member of the board of dire-ctors of a company which is a resident of the other territory,may be taxed in that other territory. Article 16 Artistes and Sportsmen 1.Notwithstanding the provisions of Articles 7 and 14, incomederived by a resident of a territory as an entertainer, suchas a theatre, motion picture, radio or television artiste, ora musician, or as a sportsman, from his personal activities assuch exercised in the other territory, may be taxed in thatother territory. 2.Where income in respect of personal activities exercised by anentertainer or a sportsman in his capacity as such accrues notto the entertainer or sportsman himself but to another person,that income may, notwithstanding the provisions of Articles 7and 14, be taxed in the territory in which the activities ofthe entertainer or sportsman are exercised. 3.The provisions of paragraphs 1 and 2 shall not apply to incomederived from activities performed in a territory by artistesor sportsmen if the visit to that territory is wholly or main-ly supported by public funds of one or both of the territoriesor subdivisions or local authorities thereof. In such case,the income is taxable only in the territory in which the arti-ste or the sportsman is a resident. Article 17 Pensions, Social Security Payments and Similar Payments 1.Payments received by an individual, being a resident of a ter-ritory, under the social security legislation of the other te-rritory, or under any other scheme out of funds created by th-at other territory or a subdivision or a local authority ther-eof, may be taxed in that other territory. 2.Subject to the provisions of paragraph 1 of this Article andparagraph 2 of Article 18, pensions and other similar remuner-ation arising in a territory and paid to a resident of the ot-her territory, whether in consideration of past employment ornot, shall be taxable only in the other territory.However,such pensions and other similar remuneration may be taxed inthe first-mentioned territory if a) contributions paid by the beneficiary to the pension schemewere deducted from the beneficiary’s taxable income in thefirst-mentioned territory under the law of that territory;or b) contributions paid by an employer were not taxable incomefor the beneficiary in the first-mentioned territory underthe law of that territory. 3.Pensions shall be deemed to arise in a territory if paid by apension fund or other similar institution providing pensionschemes in which individuals may participate in order to secu-re retirement benefits, where such pension fund or other simi-lar institution is recognized for tax purposes in accordancewith the laws of that territory. Article 18 Public Service 1. a) Salaries, wages and other similar remuneration, other than apension, paid by an authority administering a territory or asubdivision thereof, or by a local authority of that territ-ory, to an individual in respect of services rendered to su-ch authorities shall be taxable only in that territory. |
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