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Ν. 1986/1991

Ν. 1986/1991 (ΦΕΚ Α 189/10-12-1991) Convention for the avoidance of double taxation between Denmark and Greece

CONVENTION

BETWEEN THE GOVERNMENT OF THE HELLENIC REPUBLIC AND THE GOVERNMENT OF THE KINGDOM OF DENMARK FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT ON TAXES ON INCOME AND ON CAPITAL

The Government of the Hellenic Republic and the Government of the Kingdom of Denmark desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital have agreed as follows:

In witness whereof the undersigned, duly authorised thereto, have signed this Convention.

Done in duplicate at Copenhagen this 18th day of May 1989, in the English language.

For the Government of the    For the Government of the

Hellenic Republic    Kingdom of Denmark

PROTOCOL

The Government of the Hellenic Republic and the Government of the Kingdom of Denmark have agreed at the signing of the Convention between the two States for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital upon the following provisions which shall form an integral part of the said Convention.

Subject to the provisions in paragraph 10 of the commentaries to Article 8 in the OECD Model Convention on income and on capital (1977), payments received from the leasing of containers are, with reference to paragraph 3 of Article 12, considered as payments from the leasing of industrial equipment. However, such payments shall be treated in accordance with the OECD Recommendation after the OECD Model Convention has been revised in this respect.

In witness whereof the undersigned, duly authorised thereto, have signed this Protocol.

Done in duplicate at Copenhagen this 18th day of May 1989, in the English language.

For the Government of the    For the Government of the

Hellenic Republic     Kingdom of Denmark