Double Taxation Avoidance Agreement with Sweden

(6) Interest shall be deemed to arise in a Contracting State if the payer resides in that State. However, where the payer of the interest, whether or not he resides in a Contracting State, has in a Contracting State a permanent establishment or a fixed base on the basis of which the debt on which the interest is paid arose, and if such interest is borne by that permanent establishment or fixed base, such interest shall be deemed to have arisen in that State: in which the permanent establishment or fixed base is situated. situated. 6. Where profits include income treated separately in other Articles of this Convention, this Article shall not affect the provisions of those Articles. 6. Without prejudice to paragraph 5, profits from the sale of property of an individual who was resident in a Contracting State and who has become a resident of the other Contracting State may be taxed in the first-mentioned State if the sale of the property takes place at any time within the following four years after the date on which the person is no longer resident in the first-mentioned State. Condition. One. Where a resident of India receives income which may be taxed in Sweden under this Agreement, India shall grant, as a deduction from the income tax of that resident, an amount equal to the income tax paid in Sweden, directly or directly or by deduction of withholding tax. However, this amount may not exceed the part of the income tax calculated before deduction which is attributable to taxable income in Sweden.

2. Notwithstanding Articles 7, 14 and 15, where income from personal activities carried on by an artist or sportsman in his capacity does not derive from the artist or athlete himself but from another person, such income may be taxed in the Contracting State in which the activities of the artist or athlete are carried on. a. he is deemed to reside only in the State in which he has his permanent residence; if he has his permanent residence in both States, he is deemed to reside in the State with which his personal and economic relations are close (centre of vital interests); G.S.R. 112.-whereas the attached Convention for the Avoidance of Double Taxation of Income has been ratified between the Government of India and the Royal Government of Sweden and the instruments of ratification have been exchanged in accordance with Article XX of the said Convention: 7. Without prejudice to the foregoing provisions of this Article, an insurance undertaking of a Contracting State, except in respect of reinsurance, shall be deemed to be the national territory of a permanent establishment situated in the other Contracting State if it collects premiums in the territory of that other State or insures risks situated therein by a person other than a self-employed person to whom paragraph 8 applies. 4. Paragraphs 1 and 2 shall not apply where the beneficial owner of the dividends resident in a Contracting State carries on business in the other Contracting State in which the company paying dividends is resident, through a permanent establishment situated therein, or provides independent personal services in that other State from a fixed registered office, and the holding for which the dividends are distributed: is in fact associated with that permanent establishment or fixed base. In this case, Article 7 or Article 14 Application. This paragraph shall be without prejudice to the taxation of the profits of the company from which the dividends are distributed. 8. An enterprise shall not be considered a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, commissioner general or other independent representative, provided that such persons act in the ordinary course of their business.

However, where the activities of such a representative are carried out wholly or almost exclusively on behalf of that undertaking, he shall not be considered to be an independent representative within the meaning of this paragraph. All cases giving rise to double taxation as a result of the application of this Article may be settled in accordance with the reciprocity procedure. Competent authorities shall exchange information (i.e. information available to them under their respective tax laws in the context of normal administration) which is necessary for the implementation of this Agreement. The information thus exchanged shall be kept secret and shall not be disclosed to persons other than persons involved in the determination and collection of taxes covered by this Agreement. The competent authority of one of the territories that discloses commercial, commercial, industrial or professional secrets or commercial procedures to the authority of the other territory shall not exchange the above information. 1. The taxation of income in the respective Contracting States shall continue to be governed by the laws in force in one of the two Contracting States, except as otherwise provided in this Convention.

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