in Denmark. (i) the income tax to the State (indkomstskatten til staten);
(ii) the municipal income tax (den kommunale indkomstskat);
(iii) the income tax to the county municipalities (den amtskommunale indkomstskat);
(iv) the old age pension contribution (folkepensionsbidraget);
(v) the seamen's tax (somandsskatten);
(vi) the special income tax (den saerlige indkomstskat);
(vii) the church tax (kirkeskatten);
(viii) the tax on dividends (udbytteskatten);
(ix) the contribution to the sickness "per diem" fund (bidrag til dagpengefonden);
(x) the hydrocarbon tax (kulbrinteskatten); (hereinafter referred to as "Danish tax").
in Denmark. (i) the income tax to the State (indkomstskatten til staten);
(ii) the income tax to the municipalities (den kommunale indkomstskat);
(iii) the income tax to the county municipalities (den amtskommunale indkomstskat);
(iv) taxes imposed under the Hydrocarbon Tax Act (skatter i henhold til kulbrinteskatteloven); (hereinafter referred to as "Danish tax");
in Denmark. (a) subject to the provisions of sub-paragraph (c), where a resident of Denmark derives income which, in accordance with the provisions of this Agreement, may be taxed in Singapore, Denmark shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Singapore;
(b) such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income which may be taxed in Singapore;
(c) where a resident of Denmark derives income which, in accordance with the provisions of this Agreement shall be taxable only in Singapore, Denmark may include this income in the tax base, but shall allow as a deduction from the income tax that part of the income tax, which is attributable to the income derived from Singapore;
(d) where dividends are paid by a company which is a resident of Singapore to a company which is a resident of Denmark, and which owns directly or indirectly not less than 25% of the share capital of the first-mentioned company, then such dividends shall be exempt from tax in Denmark.
in Denmark in respect of taxes for the income year beginning on or after 1 January 2001 and subsequent income years;
in Denmark. (i) in respect of taxes withheld at source, on income derived on or after 1 January in the calendar year next following the year in which the Protocol enters into force;
(ii) in respect of other taxes on income, to such taxes chargeable for any tax year beginning on or after 1 January in the calendar year next following the year in which the Protocol enters into force. IN WITNESS WHEREOF the undersigned, being duly authorised thereto by their respective Governments, have signed this Protocol. DONE in duplicate at Singapore this seventeenth day of May of the year one thousand nine hundred and ninety-four in the English language. For the Government of the Republic of Singapore For the Government of the Kingdom of Denmark KOH XXXX XXXX JENS XXXXX XXXXXX The Government of the Republic of Singapore and Government of the Kingdom of Denmark. Desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income. Have agreed as follows:
1. The taxes which are the subject of this Convention are
in Denmark. (i) in respect of taxes withheld at source, on income derived on or after 1 January in the calendar year next following the year in which the Protocol enters into force;
(ii) in respect of other taxes on income, to such taxes chargeable for any tax year beginning on or after 1 January in the calendar year next following the year in which the Protocol enters into force. IN WITNESS WHEREOF the undersigned, being duly authorised thereto by their respective Governments, have signed this Protocol. DONE in duplicate at Singapore this seventeenth day of May of the year one thousand nine hundred and ninety-four in the English language. For the Government of the Republic of Singapore For the Government of the Kingdom of Denmark KOH XXXX XXXX JENS XXXXX XXXXXX The Government of the Republic of Singapore and Government of the Kingdom of Denmark. Desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income. Have agreed as follows:
1. The taxes which are the subject of this Convention are
(a) in the Republic of Singapore: the income tax (hereinafter referred to as "Singapore tax"); and
(b) in the Kingdom of Denmark:
(i) the ordinary income taxes to the State;
(ii) the municipal income taxes;
(iii) the old age pension contribution;
(iv) the seamen's tax;
(v) the special income tax (capital gains tax);
(vi) the church tax (hereinafter referred to as "Danish tax").
2. This Convention shall also apply to any other taxes of a substantially similar character to those referred to in the preceding paragraph imposed in either Contracting State after the date of signature of this Convention.
1. In this Convention, unless the context otherwise requires:
in Denmark. (a) Subject to the provisions of sub·paragraph (c), where a resident of Denmark derives income which, in accordance with the provisions of this Convention, may be taxed in Thailand, Denmark shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Thailand;
(b) such deduction shall not, however, exceed that part of the Danish income tax, as computed before the deduction is given, which is attributable to the income which may be taxed in Thailand;
(c) where a resident of Denmark derives income which, in accordance with the provisions of this Convention shall be taxable only in Thailand, Denmark may include this income in the tax base, but shall allow as a deduction from the income tax that part of the income tax, which is attributable to the income derived from Thailand.
(d) Where exemption from or reduction of Thai tax payable in accordance with the provisions of Article 7 in respect of profits derived by a Danish enterprise from a permanent establishment situated in Thailand has been granted under Thai law, then, for the purposes of sub·paragraph
(a) and sub-paragraph (b), deduction from Danish tax for Thai tax shall be allowed as if no such exemption or reduction had been granted, provided the permanent establishment is engaged in business activities (other than business activities in the financial sector) and that no more than 25 per cent of such profits consist of interest and gains from the alienation of shares and bonds or consist of profits derived from third States.
(e) Where dividends are paid by a company which is a resident of Thailand to a person (being a company) which is a resident of Denmark, and which owns directly or indirectly not less than 25 per cent of the share capital of the first·mentioned company, then such dividends shall be exempt from tax in Denmark, provided that the company paying the dividends is engaged in business activities (other than business activities in the financial sector) and that no more than 25 per cent of the company's profits consist of interest and gains from the alienation of shares and bonds or consist of profits derived from third States.
(f) For the purposes of sub-paragraphs (a) and (b) of this paragraph, in the case of royalties paid as a consideration for the use of, or the right to use, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific e...
in Denmark. (i) the income tax to the State (indkomstskatten til staten);
(ii) the municipal income tax (den kommunale indkomstskat);
(iii) the income tax to the county municipalities (den amtskommunale indkomstskat);
(iv) the special income tax (den særlige indkomstskat);
(v) the church tax (kirkeskatten);
(vi) the tax on dividends (udbytteskatten);
(vii) the tax on interest (renteskatten);
(viii) the tax on royalties (royaltyskatten);
(ix) taxes imposed under the Hydrocarbon Tax Act (skatter i henhold til kulbrinteskatteloven); and
(x) the capital tax to the State (formueskatten til staten); (hereinafter referred to as "Danish tax").
in Denmark a) Subject to the provisions of sub-paragraph c), where a resident of Denmark derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in Macedonia, Denmark shall allow:
(i) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Macedonia;
(ii) as a deduction from the tax on capital of that resident, an amount equal to the capital tax paid in Macedonia;
b) such deduction in either case shall not, however, exceed that part of the income tax or capital tax, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital which may be taxed in Macedonia;
c) where a resident of Denmark derives income or owns capital which, in accordance with the provisions of this Convention, shall be taxable only in Macedonia, Denmark may include this income or capital in the tax base, but shall allow as a deduction from the income tax or capital tax that part of the income tax or capital tax which is attributable, as the case may be, to the income derived from or the capital owned in Macedonia.
in Denmark re Article 15:
