The pending protocol to the 1996 tax treaty between Denmark and the Netherlands was signed on 9 May 2018. The protocol is the first to amend the treaty and includes the following changes:
- A new title and preamble in line with BEPS standards;
- The amendment of Article 2 (Taxes Covered) in respect of both countries;
- The removal of provisions regarding the taxation of capital, including the removal of Article 22 (Capital), as well as certain references to capital in Article 23 (Elimination of Do…