Tax Treaty between Canada and Denmark

The Agreement between Canada and the Federal Republic of Germany, signed on July 17, 1981. – Return – The agreement between Canada and Switzerland, signed on May 5, 1997 and amended by a protocol signed on October 22, 2010. The new agreement between Canada and the Czech Republic, signed on May 25, 2001 (GAC website). The Treaty entered into force on 28 May 2002. For more details, see News Release 2001-052. The Tax Convention between Canada and the Republic of Bulgaria, as signed on March 3, 1999 (GAC website). – Declaration – At the time of signature of the Convention for the Prevention of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital between the Government of Canada and the Government of the Kingdom of Denmark, the Signatories agreed that the following provisions will form an integral part of the Agreement: the Agreement between Canada and the United States of America, as amended by the Protocols signed on June 14, 1983, March 28, 1984, March 17, 1995, July 29, 1997 and September 21, 2007. and, in both cases, conditions are established or imposed between the two enterprises in their commercial or financial relations which are different from those which would be obtained between independent undertakings, and then the income or profits which, in the absence of those conditions, would have been paid to one of the undertakings but which did not arise as a result of those conditions; may be included in the income or profits of that company and taxed accordingly. The Agreement between the Government of the Republic of Kazakhstan and the Government of Canada, signed on September 25, 1996 (GAC website). – Return – Protocol amending the Agreement between Canada and Switzerland, as signed on October 22, 2010. In order to avoid double taxation of income, Denmark has concluded DVB-TS with a large number of countries. All tax treaties contain rules for the exchange of tax information, and specific EU rules also apply. Double taxation can also occur in the context of inheritance tax.

To remedy this situation, Denmark has concluded contracts in this regard with the other Scandinavian countries, Germany, Italy, Switzerland and the United States. The countries with which Denmark currently has the DVB-T and where the contract contains a remuneration clause are:. THE GOVERNMENT OF CANADA AND THE GOVERNMENT OF THE KINGDOM OF DENMARK. This Convention shall apply to persons established in one or both Contracting States. . Copyright and other similar payments made for the production or reproduction of literary, dramatic, musical or artistic works (but excluding rents or royalties for cinematographic works) from a resident of the other territory from sources in one of the territories are exempt in that former territory. . Under this Article, either Contracting Government shall not be deemed to be required to disclose to the other Government any information other than that which its own tax rules permit it to provide or information the provision of which would result in the disclosure of industrial, trade or professional secrets or business processes. .

Directors` fees and other similar remuneration received by a resident of a Contracting State in his capacity as a member of the management or similar organ of a company established in the other Contracting State may be taxed in that other State. The Canada-Hong Kong Income Tax Convention, signed on November 11, 2012. – Returns – Unused credits are non-refundable and cannot be returned or passed on. born in a Contracting State and paid to a resident of the other Contracting State who is the beneficial owner of the Contracting State shall be subject to tax only in that other State. . The terms “foreign subsidiary” and “tax-exempt surplus” have the meaning they have under Canada`s Income Tax Act. Nor shall these provisions be regarded as an obligation for either of the two Contracting Governments to carry out an administrative act which would be contrary to their rules or practices. Activities related to preliminary investigations, exploration or extraction of hydrocarbons The Second Canada-New Zealand Protocol, signed on September 12, 2014. . .

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