Bilag 2.



The Minister of Taxation, Copenhagen, Denmark, acting through and represented by

[ Designation ]


Bank Guarantee as security for keeping the recovery of tax demand in abeyance during the pendency of a Mutual Agreement Procedure ("MAP").

[Applicable in case of non-resident assessees, and Danish companies and

other entities affiliated with Indian companies, who have invoked the

Mutual Agreement Procedure]

[Name of beneficiary]


Guarantee number:

At the request and for the account of [name of applicant]

we hold at your disposal DKK [.....]

(spell out amount: .....)

The amount relates to a tax claim regarding ..... (brief description of the claim) and will be paid to you on demand without legal proceedings and without prior notice to the applicant.

This Guarantee is valid until further notice. 

This Guarantee may be terminated by us by in writing by registered letter to the beneficiary at three months' notice from the end of a month. If the applicant fails, upon demand from the beneficiary, to furnish other adequate security to the beneficiary before the expiry of the period of notice, the beneficiary may demand the deposit of the guarantee amount in security of the tax claim covered by this Guarantee. Such demand must reach us not later than 30 (thirty) days after the expiry of this Guarantee according to the notice given.

If we do not receive claims under this Guarantee in writing on the date indicated above at the latest, we are under no obligation to make any payment, and this Letter of Guarantee must be returned to us.

If it is later determined that the amount paid under this Guarantee was too large, for example because the estimated amount of a claim was initially too large, the excess amount must be repaid. Please note that the applicant has assigned the right to claim repayment to us, which means that any repayment must be made only to us.

Any dispute arising out of this Guarantee will be governed by Danish law and must be brought before a Danish court.

Place and date

Name of branch