A Protocol to Double Taxation Avoidance Agreement between India
and Denmark that has entered into force on February 1, 2015, has
been notified by Notification No. 45/2015/F No.
503/02/1998-FDI-I, to expand the scope of Exchange of
Information (EOI) clause under Article 26 by substituting the same
with a new Article 26.
In terms of newly substituted Article 26, the said clause has
been liberalized to allow exchange of information as is foreseeably
relevant for, inter alia, administration, or enforcement
of domestic laws. Clauses 4 and 5 have been newly inserted to
– (a) debar the contracting states from declining to supply
information requested solely on the ground of "no domestic
interest" in such information and makes it obligatory for
the contracting states to provide information requested by other
states even when the other state may not need the information for
its own tax purpose and (b) prohibits contracting states from
denying information solely "because the
