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TMI BlogProtocolX X X X Extracts X X X X X X X X Extracts X X X X ..... a taxpayer shall not be made unless such taxes aggregate to 2000 Danish Crowns or its equivalent in Indian currency or more. 1[(3) With reference to Article 26, it is understood that as stated in paragraph 9.1 of OECD commentary on Article 26, the new wordings (as per 2010 version) of Article 26 covers Tax Examinations Abroad.] IN WITNESS WHEREOF the undersigned, duly authorised thereto, have signed the present Protocol. Done in duplicate at Copenhagen this 8th day of March, one thousand nine hundred eighty-nine in Hindi, Danish and English languages, all the texts being equally authentic. In case of divergence between the three texts, English text shall be the operative one. PROTOCOL At the moment of signing the Convention for the avo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 8th day of March, one thousand nine hundred and eighty-nine in Hindi, Danish and English languages, all the texts being equally authentic. In case of divergence between any of the texts, the English text shall be the operative one. 2[PROTOCOL AMENDING THE CONVENTION BETWEEN THE REPUBLIC OF INDIA AND THE KINGDOM OF DENMARK FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL, AND THE PROTOCOL ON PROVISIONS ON CLARIFICATION OF THE CONVENTION WHICH WERE BOTH SIGNED AT COPENHAGEN ON 8TH MARCH, 1989. The Government of the Republic of India and the Government of the Kingdom of Denmark; Desiring to conclude a Protocol (hereinafter referred to as "Amending Protocol" ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t restricted by Articles 1 and 2. 2. Any information received under paragraph 1 by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement or prosecution in respect of, the determination of appeals in relation to the taxes referred to in paragraph 1, or the oversight of the above. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions. Notwithstanding the foregoing, information received by a Contracti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rovisions of paragraph 3 be construed to permit a Contracting State to decline to supply information solely because the information is held by a bank, other financial institution, nominee or person acting in an agency or a fiduciary capacity or because it relates to ownership interests in a person." Article 2 The following paragraph 3 shall be inserted after paragraph 2 of the Protocol to the Convention on provisions on clarification of the Convention: "3. With reference to Article 26, it is understood that as stated in paragraph 9.1 of OECD commentary on Article 26, the new wordings (as per 2010 version) of Article 26 covers Tax Examinations Abroad." Article 3 1. Each of the Contracting States shall notify to the other ..... X X X X Extracts X X X X X X X X Extracts X X X X
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