DT5968 - DT: Denmark: double taxation agreement, Article 19: Government service
(1)
- Remuneration, other than a pension, paid by a Contracting State
or a political subdivision or a local authority thereof to an
individual in respect of services rendered to that State or
subdivision or authority shall be taxable only in that State.
- However, such remuneration shall be taxable only in the other
Contracting State if the services are rendered in that State and
the individual is a resident of that State who:
(i) is a national of that State; or
(ii) did not become a resident of that State solely for the purpose of rendering the services.
- Notwithstanding the provisions of sub-paragraph (b)(ii) of this
paragraph, the provisions of sub-paragraph (a) shall apply to
remuneration paid to:
(i) employees at the British Embassy or at the British Council in Copenhagen who are not nationals of Denmark, and
(ii) employees at the Danish Embassy in London who are not nationals of the United Kingdom.
(2)
- Any pension paid by, or out of funds created by, a Contracting
State or a political subdivision or a local authority thereof to an
individual in respect of services rendered to that State or
subdivision or authority shall be taxable only in that State.
- However, such pension shall be taxable only in the other
Contracting State if the individual is a resident of, and a
national of, that State.
(3) The provisions of Articles 15, 16 and 18 shall apply to remuneration and pensions in respect of services rendered in connection with a business carried on by a Contracting State or a political subdivision or a local authority thereof.
