Update – Pending Protocol to the Tax Treaty between Denmark and the Netherlands

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…