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Protocol to Tax Treaty between Brazil and Denmark has Entered into Force

01 July 2019

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Treaty Development

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Brazil-Denmark

The protocol to the 1974 income tax treaty between Brazil and Denmark entered into force on 20 March 2019. The protocol, signed 23 March 2011, replaces Article 23 (Methods for the Elimination of Double Taxation), including that both countries will generally apply the credit method for the elimination of double taxation, and that dividends received by residents of Denmark from Brazil will not be treated less favorably than dividends paid and received between Danish resident companies in similar conditions (Denmark generally exempts dividends paid on subsidiary shares with at least 10% holding). Further to the Article 23 change, the pending...