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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Denmark: double taxation agreement: Exchange of Notes

With reference to Articles 10(6), 11(6) and 12(5) of the Convention as amended by the protocol, in the event that a resident of a Contracting State is denied relief from taxation in the other Contracting State by reason of one of those provisions, the competent authority of that other Contracting State shall notify the competent authority of the first-mentioned Contracting State; and

With reference to Article 22 of the Convention, by continuing to use the criterion of a holding of a voting power in paragraph (1)(b) of Article 22 the Contracting States are exercising the option provided in paragraph 2 of Article 23 of Council Directive 90/435 EEC of 23rd July 1990 to derogate from paragraph 1 of that Article by replacing the criterion of a holding in the capital of a company of another Member State by that of a holding of voting rights.