Explanation of Proposed Income Tax Treaty and Proposed Protocol Between the United States and the Kingdom of Denmark: Scheduled for a Hearing Before the Committee on Foreign Relations, United States Senate, on October 13, 1999U.S. Government Printing Office, 1999 - 58 pages |
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Common terms and phrases
50 percent activities apply Article attributable base erosion test business profits Code competent authority coun country of residence country tax Danish hydrocarbon tax Danish taxable nonstock Danish taxes derivative benefits dividends dividends paid double taxation effectively connected enterprise entitled to treaty entity establishment or fixed exemption fixed base foreign corporation foreign tax credit Hydrocarbon Tax Act income tax treaties independent personal services individual interest internal law international traffic NAFTA nonresident alien OECD model pension permanent establishment posed treaty proposed protocol proposed treaty contains Proposed treaty limitations proposed treaty provides real property REMIC resi revenue claim royalties saving clause ships or aircraft similar taxable nonstock corporation taxes imposed taxes paid taxpayer Technical Explanation third country tion trade or business treaty benefits treaty country U.S. citizens U.S. corporation U.S. income tax U.S. law U.S. model U.S. person U.S. resident U.S. tax treaties U.S. trade U.S. treaties U.S.-source income withholding tax
Popular passages
Page 18 - State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment.
Page 48 - ... administrative practice of that or of the other Contracting State; b) to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State; c) to supply information which would disclose any trade, business, industrial. commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public).
Page 48 - Any information received by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State...
Page 46 - Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more...
Page 21 - State, and in either case 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, then any profits which would, but for those conditions have accrued to one of the enterprises, but by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
Page 15 - ... the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character...
Page 34 - annuity ' means a stated sum payable periodically at stated times during life or during a specified or ascertainable period of time under an obligation to make the payments in return for adequate and full consideration in money or money's worth. Article 19.
Page 16 - immovable property' shall have the meaning which it has under the law of the Contracting State in which the property in question is situated. The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits,...
Page 15 - permanent establishment' means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term 'permanent establishment...
Page 17 - States (under what is referred to as a "force of attraction" rule). Foreign-source income generally is effectively connected income only if the foreign person has an office or other fixed place of business in the United States and the income is attributable to that place of business.