G.S.R. 316.-Considering that the attached Convention for the Avoidance of Double Taxation of Income has been ratified between the Governments of India and Denmark and that the instruments of ratification have been exchanged in accordance with Article XX of the said Convention: I should be grateful if you would confirm your agreement to the above-mentioned understanding of the provisions of Article VI of the said Convention and that, in this case, this reference and your response in the context of compatibility 1996, 1990, 1 To avoid double taxation of income, Denmark has concluded DTTs with a large number of countries. All tax treaties contain rules for the exchange of tax information and specific EU rules also apply. Double taxation can also occur with regard to inheritance tax. To remedy this situation, Denmark has concluded agreements in this regard with the other Scandinavian countries, Germany, Italy, Switzerland and the United States. Countries with which Denmark currently has DTT and in which the contract contains a remuneration clause: in both cases, conditions different from those which would be achieved between independent undertakings are taken or imposed between the two undertakings in their commercial or financial relations, so that all profits which, without those conditions, would have been paid to one or other of the undertakings, may: but, under those conditions, were not so taxed in the profits of that undertaking and accordingly. All information thus exchanged shall be treated in secret and may not be disclosed to persons other than those responsible for the fixing and collection of the fees which are the subject of this Agreement. The competent authority of either zone may not exchange information in the above-mentioned case which would disclose to the authority of the other region any commercial, commercial, industrial or professional secrets or commercial procedures. The Uttarakhand High Court recently ruled that, in accordance with Article 16(2) of the Double Taxation Convention, the country of residence was not relevant until an employer was established. .