【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7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] b) However, such salaries, wages and other similar remunerationshall be taxable only in the other territory if the servicesare rendered in that territory and the individual is a resi-dent of that territory who: (i) is a national of that territory under the laws in force inthat territory; or (ii) did not become a resident of that territory solely forthe purpose of rendering the services. 2. a) Any pension paid by, or out of funds created by, an authori-ty administering a territory or a subdivision thereof, or alocal authority of that territory, to an individual in resp-ect of services rendered to such authorities shall be taxab-le only in that territory. b) However, such pension shall be taxable only in the other te-rritory if the individual is a resident of and, under the laws in force in that territory, a national of that territo-ry. 3.The provisions of Articles 14, 15, 16 and 17 shall apply tosalaries, wages and other sim-ilar remuneration, and to pensi-ons, in respect of services rendered in connection with a bus-iness carried on by an authority referred to in paragraph 1.Article 19 Students Payments which a student or business apprentice who is or wasimmediately before visiting a territory a resident of the otherterritory and who is present in the first-mentioned territorysolely for the purpose of his education or training receives forthe purpose of his maintenance, education or training shall notbe taxed in that territory, provided that such payments arisefrom sources outside that territory. Article 20 Other Income 1.Items of income of a resident of a territory, wherever arising, not dealt with in the foregoing Articles of this Agreementshall be taxable only in that territory. 2.The provisions of paragraph l shall not apply to income, otherthan income from immovable property as defined in paragraph 2of Article 6, if the recipient of such income, being a reside-nt of a territory, carries on business in the other territorythrough a permanent establishment situated therein, and theright or property in respect of which the income is paid iseffectively connected with such permanent establishment. Insuch case the provisions of Article 7 shall apply. 3.Notwithstanding the provisions of paragraphs 1 and 2, items ofincome of a resident of a territory not dealt with in the for-egoing Articles of the Agreement and arising in the other ter-ritory may also be taxed in that other territory. Article 21 Elimination of Double Taxation Double taxation shall be avoided as follows: 1.In the case of the territory where the taxation laws administ-ered by the Danish Ministry of Taxation are applied: a) Subject to the provisions of subparagraph c), where a resid-ent of the territory where the taxation laws administered bythe Danish Ministry of Taxation are applied derives incomewhich, in accordance with the provisions of this Agreement,may be taxed in the territory where the taxation laws admin-istered by the Taxation Agency, Ministry of finance in Taip-ei are applied, the first mentioned territory shall allow asa deduction from the tax on the income of that resident, anamount equal to the income tax paid in the other territory;b) such deduction shall not, however, exceed that part of theincome tax as computed before the deduction is given, whichis attributable to the income which may be taxed in the oth-er territory; c) where a resident of the territory where the taxation lawsadministered by the Danish Ministry of Taxation are appliedderives income which, in accordance with the provisions ofthis Agreement shall be taxable only in the territory wherethe taxation laws administered by the Taxation Agency, Mini-stry of Finance in Taipei are applied, the first mentionedterritory may include this income in the tax base, but shallallow as a deduction from the income tax that part of the income tax, which is attributable to the income derived fromthe other territory. 2.In the case of the territory where the taxation laws administ-ered by the Taxation Agency, Ministry of Finance in Taipei areapplied: Where a resident of the territory where the taxation laws adm-inistered by the Taxation Agency, Ministry of Finance in Taip-ei are applied derives income from the other territory wherethe taxation laws administered by the Danish Ministry of Taxa-tion are applied, the amount of tax on that income paid in theother territory and in accordance with the provisions of thisAgreement, shall be credited against the tax levied in the fi-rst mentioned territory imposed on that resident. The amountof credit, however, shall not exceed the amount of the tax inthe first mentioned territory on that income computed in acco-rdance with its taxation laws and regulations. Article 22 Non-Discrimination 1.Nationals of a territory under the laws in force in that terr-itory shall not in the other territory be subjected to any ta-xation or any requirement connected therewith, which is otheror more burdensome than the taxation and connected requiremen-ts to which nationals of that other territory under the lawsin force in that other territory in the same circumstances, inparticular with respect to residence, are or may be subjected.This provision shall, notwithstanding the provisions of Artic-le l, also apply to persons who are not residents of one orboth of the territories. |
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