Denmark has 71 tax agreements in force, as reported in its response to the Peer Review questionnaire, including the multilateral Nordic Convention concluded with Finland, Iceland, Norway and Sweden (the “Nordic Convention”).1 19 of those agreements, the agreements with Australia, Belgium, Canada, India, Ireland, Israel, Japan, Lithuania, Luxembourg, Malta, the Netherlands, New Zealand, Poland, Serbia, the Slovak Republic, Slovenia, Ukraine, the United Kingdom and the Nordic Convention, comply with the minimum standard.

Denmark signed the MLI in 2017 and deposited its instrument of ratification on 30 September 2019. The MLI entered into force for Denmark on 1 January 2020. Denmark has not listed its agreements with Armenia, Germany, and Switzerland, but has indicated its intention to notify its agreement with Armenia under the MLI. These agreements will therefore not, at this stage, be modified by the MLI.

The Parties to the Nordic Convention signed a complying instrument in 2018. The protocol entered into force on 28 November 2019 and its provisions took effect on 1 January 2020.

Denmark is implementing the minimum standard through the inclusion of the preamble statement and the PPT.2

The agreements modified by the MLI come into compliance with the minimum standard once the provisions of the MLI take effect.

As mentioned above, Denmark has not listed its agreements with Armenia, Germany and Switzerland under the MLI. Listing the agreements under the MLI or entering into bilateral renegotiations to implement the minimum standard would ensure that the minimum standard could be implemented in those non-covered agreements.


← 1. See the Multilateral convention concluded by Denmark, Finland, the Faroe Islands, Iceland, Norway and Sweden: for the avoidance of double taxation with respect to taxes on income and on capital (1996, 1997, 2008 and 2018). In total, Denmark identified 74 "agreements" in its List of Tax agreements: 70 bilateral agreements and the Nordic Convention concluded with four of its treaty partners.

← 2. For its agreements listed under the MLI, Denmark is implementing the preamble statement (Article 6 of the MLI) and the PPT (Article 7 of the MLI). Denmark has also accepted to implement a simplified LOB in agreements concluded with partners that opted in for the simplified LOB (Article 7(7)(a) of the MLI).

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