Denmark: Taxation of Income from Independent Personal Services? – Article 14 of the Denmark/China Tax Treaty

Søren Friis Møller

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There were no reported tax treaty cases from the Danish Supreme Court or the two Danish High Courts in 2020. There are, however, a number of reported binding rulings from the Tax Assessment Council (Skatterådet, abbreviated in Danish to SR, here as TAC). The binding ruling, reported as SKM2020.382.SR,[2] deals with the question of whether profits from independent personal services provided in China are taxable in Denmark because the taxpayer’s stay in Denmark was prolonged beyond 90 days due to Covid 19 restrictions. The ruling is based upon § 1, stk. 1, nr. 1 of the Act on Taxation at Source (kildeskatteloven, or ‘TSA’)[3] and Article 14 of the Denmark-China tax treaty
Original languageEnglish
Title of host publicationTax Treaty Case Law around the Globe 2021
EditorsGeorg Kofler, Michael Lang, Alexander Rust, Jeffrey Owens, Pasquale Pistone, Josef Schuch, Karoline Spies, Claus Staringer, Alfred Storck, Peter Essers, Eric C.C.M Kemmeren, Cihat Öner, Daniël Smit
Number of pages4
Place of PublicationWien
PublisherLinde Verlag Wien
Publication date2022
ISBN (Print)9783707345476, 9789087227876
ISBN (Electronic)9783709412336, 9789087227890, 9783707312343, 9789087227883
Publication statusPublished - 2022
SeriesSeries on International Tax Law

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