Denmark
A. Progress in the implementation of the minimum standard
Denmark has 72 tax agreements in force as reported in its response to the Peer Review questionnaire, including the multilateral Nordic Convention concluded with the Faroe Islands, Finland, Iceland, Norway and Sweden (the Nordic Convention).1 Thirty of those agreements, including 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. The agreements modified by the MLI come into compliance with the minimum standard once the provisions of the MLI take effect.
Denmark has not listed its agreements with Germany and Switzerland under the MLI. These agreements will therefore not, at this stage, be modified by the MLI. Denmark has signed a bilateral complying instrument with respect to its agreements with Germany and Sri Lanka, and indicated in its response to the Peer Review questionnaire that steps have been taken (other than under the MLI) to implement the minimum standard in its agreements with Greenland and Switzerland.
Denmark is implementing the minimum standard through the inclusion of the preamble statement and the PPT.2
← 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 76 "agreements" in its List of Tax agreements: 71 bilateral agreements and the Nordic Convention concluded with five 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). Under Article 7(7)(a) of the MLI, Denmark is also implementing the simplified LOB (Article 7(8 to 13) of the MLI) in agreements concluded with treaty partners that have adopted the simplified LOB.