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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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Denmark: double taxation agreement, Article 3: General definitions

  1. In this Convention, unless the context otherwise requires:

 

  1. the term `United Kingdom` means Great Britain and Northern Ireland, including any area outside the territorial sea of the United Kingdom which in accordance with international law has been or may hereafter be designated, under the laws of the United Kingdom concerning the Continental Shelf, as an area within which the rights of the United Kingdom with respect to the sea bed and sub-soil and their natural resources may be exercised;
  2. the term `Denmark` means the Kingdom of Denmark, including any area outside the territorial sea of Denmark which in accordance with international law has been or may hereafter be designated under Danish laws as an area within which Denmark may exercise sovereign rights with respect to the exploration and exploitation of the natural resources of the sea-bed or its subsoil; the term does not comprise the Faroe Islands and Greenland.
  3. the term `national` means:
(i) in relation to the United Kingdom, any British citizen or any British subject not possessing the citizenship of any other Commonwealth country or territory, provided he has the right of abode in the United Kingdom; and any legal person, partnership, association or other entity deriving its status as such from the law in force in the United Kingdom;  


(ii) in relation to Denmark, any individual possessing the nationality of Denmark and any legal person, partnership or association deriving its status as such from the law in force in Denmark;  
  1. the term `tax` means United Kingdom tax or Danish tax, as the context requires;
  2. the terms ‘a Contracting State’ and ‘the other Contracting State’ mean the United Kingdom or Denmark, as the context requires;
  3. the term ‘person’ comprises an individual, a company and any other body of persons, but does not include partnerships;
  4. the term ‘company’ means any body corporate or any entity which is treated as a body corporate for tax purposes;
  5. the terms ‘enterprise of a Contracting State’ and ‘enterprise of the other Contracting State’ mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State;
  6. the term ‘international traffic’ means any transport by a ship or aircraft operated by an enterprise of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State;
  7. the term ‘competent authority’ means in the case of the United Kingdom the Commissioners of Inland Revenue or their authorised representative, and in the case of Denmark the Minister for Inland Revenue, Customs and Excise or his authorised representative.

 

  1. As regards the application of the Convention by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of that State concerning the taxes to which the Convention applies.