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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
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Denmark: double taxation agreement, Article 8: Shipping and air transport

  1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
  2. For the purposes of this Article, profits from the operation of ships or aircraft in international traffic include:

 

 

  1. profits from the rental on a bareboat basis of ships or aircraft; and
  2. profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise;

where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.

  1. The provisions of paragraphs (1) and (2) of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency, but only to so much of the profits so derived as is attributable to the participant in proportion to its share in the joint operation.
  2. With respect to profits derived by the Danish, Norwegian and Swedish air transport consortium, known as the Scandanavian Airlines System (SAS), the provisions of paragraphs (1), (2) and (3) of this Article shall apply only to such proportion of the profits as corresponds to the participation in that consortium by Det Danske Luftfartsselskab (DDL), the Danish partner of the Scandanavian Airlines System (SAS).