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Update – Pending Protocol to the Tax Treaty between Denmark and the Netherlands

01 June 2018

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Treaty Development

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Denmark-Netherlands

The pending protocol to the 1996 tax treaty between Denmark and the Netherlands was signed on 9 May 2018. The protocol is the first to amend the treaty and includes the following changes: A new title and preamble in line with BEPS standards; The amendment of Article 2 (Taxes Covered) in respect of both countries; The removal of provisions regarding the taxation of capital, including the removal of Article 22 (Capital), as well as certain references to capital in Article 23 (Elimination of Double Taxation), Article 25 (Non-Discrimination), Article 30 (Miscellaneous Rules), and the final protocol originally signed with the...