DT5973 - DT: Denmark: double taxation agreement, Article 24: Mutual agreement procedure
- Where a person considers that the actions of one or both of the
Contracting States result or will result for him in taxation not in
accordance with the provisions of this Convention, he may,
irrespective of the remedies provided by the domestic law of those
States, present his case to the competent authority of the
Contracting State of which he is a resident.
- The competent authority shall endeavour, if the objection
appears to it to be justified and if it is not itself able to
arrive at a satisfactory solution, to resolve the case by mutual
agreement with the competent authority of the other Contracting
State, with a view to the avoidance of taxation which is not in
accordance with the Convention.
- The competent authorities of the Contracting States shall
endeavour to resolve by mutual agreement any difficulties or doubts
arising as to the interpretation or application of the Convention.
They may also consult together to consider measures to counteract
improper use of the provisions of the Convention.
- The competent authorities of the Contracting States may
communicate with each other directly for the purpose of reaching an
agreement in the sense of the preceding paragraphs.
