<p>2018 Armenia-Denmark Income and Capital Tax Treaty Available</p>

2018 Armenia-Denmark Income and Capital Tax Treaty Available

<p>Tax Analysts has obtained the English text of the Armenia-Denmark income and capital tax treaty signed March 14, 2018, in Copenhagen.</p> <p>Under the treaty, dividends are taxable at 0 percent if the beneficial owner is a company that directly holds at least 50 percent of the capital of the payer company and has invested more than €2 million (or its equivalent in Armenian or Danish currency) in the capital of the payer company. A 5 percent rate applies to dividends if the beneficial owner is a company that directly holds at least 10 percent of the capital of the payer company and has invested more than €100,000 (or its equivalent in Armenian or Danish currency) in the capital of the payer company. A 15 percent rate applies in other cases. </p> <p>Interest is taxable at a maximum rate of 5 percent if the interest is paid on any loan granted by a bank. A 10 percent rate applies in other cases. A 5 percent withholding rate applies to royalties paid for the use of, or right to use, any computer software, patent, trademark, design or model, plan, secret formula or process, or for information concerning industrial, commercial, or scientific experience. A 10 percent rate applies to royalties paid for the use of, or right to use, any copyright of literary, artistic, or scientific work, including cinematograph films, and films or tapes for radio or television broadcasting. Both countries generally apply the credit method to eliminate double taxation.</p> <p>The treaty will enter into force the day after the exchange of ratification instruments, and its provisions will apply from January 1 following its entry into force.</p>

<p><a href="/lr/resolve/-/2b16g" title=" ">Armenian text</a>; <a href="/lr/resolve/-/27vxr" title=" ">Danish text</a>. <a href="/lr/resolve/-/29xp0" title=" ">Prior coverage</a>.</p>

<p>Tax Analysts has obtained the English text of the Armenia-Denmark income and capital tax treaty signed March 14, 2018, in Copenhagen. </p>

Tax Analysts has obtained the English text of the Armenia-Denmark income and capital tax treaty signed March 14, 2018, in Copenhagen. Under the treaty, dividends are taxable at 0 percent if the beneficial owner is a company that directly holds at least 50 percent of the capital of the payer company and has invested more than €2 million (or its equivalent in Armenian or Danish currency) in the capital of the payer company. A 5 percent rate applies to dividends if the beneficial owner is a company that directly holds at least 10 percent of the capital of the payer company and has invested more than €100,000 (or its equivalent in Armenian or Danish currency) in the capital of the payer company. A 15 percent rate applies in other cases.  Interest is taxable at a maximum rate of 5 percent if the interest is paid on any loan granted by a bank. A 10 percent rate applies in other cases. A 5 percent withholding rate applies to royalties paid for the use of, or right to use, any computer software, patent, trademark, design or model, plan, secret formula or process, or for information concerning industrial, commercial, or scientific experience. A 10 percent rate applies to royalties paid for the use of, or right to use, any copyright of literary, artistic, or scientific work, including cinematograph films, and films or tapes for radio or television broadcasting. Both countries generally apply the credit method to eliminate double taxation. The treaty will enter into force the day after the exchange of ratification instruments, and its provisions will apply from January 1 following its entry into force.

<h4>Rate Table Instructions</h4> <ul> <li>You must enter a rate for each rate type</li> <li>Enter only one rate value per row</li> <li>You may leave the country columns blank if the rate is the same for both countries</li> <li>Country names (if entered) must exactly match the jurisdictions</li> <li>Leave the Partner Country column blank if you want the rate to apply to all partners of the Main Country</li> <li>Enter "n/a" in each rate row to hide the partner in the Main Country table</li> <li>Note that the same rates may apply for Main Country and Partner Country or the Main Country may apply different rates to the Partner Country</li> </ul> <table> <tbody> <tr><th> <div>Rate Type</div> (Dividends, Interest, Royalties)</th><th>Main Country</th><th>Partner Country</th><th>Rate</th><th>Footnote 1</th><th>Footnote 2</th><th>Footnote 3</th><th>Footnote 4</th></tr> <tr> <td>Dividends</td> <td>0/5/15 </td> <td> </td> <td> </td> <td> </td> <td> </td> <td> </td> <td> </td> </tr> <tr> <td>Interest</td> <td>5/10 </td> <td>The 5 percent rate applies to interest paid on a loan granted by a bank. The 10 percent rate applies in other cases.</td> <td> </td> <td> </td> <td> </td> <td> </td> <td> </td> </tr> <tr> <td>Royalties</td> <td>5/10 </td> <td>The 5 percent rate applies to computer software, patent, trademark, and industrial, commercial, and scientific information royalties. The 10 percent rate applies to literary, artistic, and scientific work copyright royalties (including cinematograph films, and films and tapes for radio or television broadcasting).<br/> </td> <td> </td> <td> </td> <td> </td> <td> </td> <td> </td> </tr> </tbody> </table>

Armenia - Denmark: 2018 Income and Capital Tax Convention and Final Protocol

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2018 Armenia-Denmark Income and Capital Tax Treaty Available