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HMRC internal manual

International Manual

DT Agreements: Denmark - Income from a UK source paid to a resident of Denmark

Other income paid to a resident of Denmark (Article 21)

Full relief is available to the beneficial owner of income that is not expresslymentioned in the Articles of the United Kingdom/Denmark Double Taxation Convention.

No relief can be allowed under the terms of this article for income thatis paid out of trusts or income paid during the administration period of a UK estate.