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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 29: Entry into force

  1. This Convention shall come into force on the date when the last of all such things shall have been done in the United Kingdom and Denmark as are necessary for the entry into force in the United Kingdom and Denmark, and shall thereupon have effect:

 

  1. in the United Kingdom:
(i) in respect of income tax and capital gains tax, for any year of assessment beginning on or after 6th April, 1978;  


(ii) in respect of corporation tax, for any financial year beginning on or after 1st April, 1978;  


(iii) in respect of petroleum revenue tax, for any chargeable period beginning on or after 1st January, 1978; and  


(iv) in respect of development land tax, for any realised development value accruing on or after 1st January, 1978.  
  1. in Denmark in respect of income assessable for the calendar year 1978 and subsequent years.

 

  1. Subject to the provisions of paragraph (3) of this Article the Convention between the United Kingdom of Great Britain and Northern Ireland and the Kingdom of Denmark for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income signed at London on 27th March,1950(a), as amended by the Protocol signed at London on 7th July, 1966(b), and by the Supplementary Protocol signed at London on 18th December, 1968(c) and by the Supplementary Protocol signed at Copenhagen on 8th February, 1973(d), (hereinafter referred to as ‘the 1950 Convention’), shall terminate upon the entry into force of this Convention and thereupon cease to have effect in respect of taxes to which this Convention, in accordance with the provisions of paragraph (1) of this Article, applies.
  2. Where any provision of the 1950 Convention would have afforded any greater relief from tax any such provision as aforesaid shall continue to have effect:

 

  1. in the United Kingdom, for any year of assessment or financial year; and
  2. in Denmark, for any taxable year
  3. beginning, in either case, before 1st January, 1981.

 

  1. This Convention shall not affect any Agreement in force extending the 1950 Convention in accordance with Article XX thereof.
  2. The Agreement dated 18th December, 1924(a) between the United Kingdom and Denmark for the Reciprocal Exemption from Income Tax in certain cases of Profits accruing from the Business of Shipping shall terminate upon entry into force of this Convention.