Treaty detail
United Kingdom - Denmark tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1980-11-11
Effective
1981-12-01
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 0%
Following protocol updates, qualifying corporate parent-subsidiary cases can benefit from a zero-percent rate under the UK-Denmark treaty. The 15 percent rate applies more broadly, with article-level review recommended.
Interest
Rate: 0%
The treaty generally eliminates source-country interest withholding. Beneficial-ownership and back-to-back financing tests still apply before the zero rate is operative.
Royalties
Rate: 0%
The treaty generally eliminates withholding on qualifying royalties. The article definition controls characterization for mixed contracts.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent rules apply where an agent habitually concludes contracts in the source country. Post-MLI overlays apply to qualifying treaty provisions.
Other treaty flags
The UK-Denmark treaty divides pension rights between source and residence based on the type of pension. Government-service pensions generally follow source-country rules, and private pensions generally follow residence.
Seeded article summaries
Article 4
Residence
Defines treaty residence and underpins every other claim under the treaty.
Residence is the foundation for every other UK-Denmark treaty claim. Dual-residence questions for individuals and companies are resolved using the tiebreaker rules in this article.
Article 5
Permanent Establishment
Defines the source-country business-presence threshold.
Article 5 follows the OECD model with a twelve-month construction threshold. Service-based and agent-based PE questions deserve article-level review under the post-protocol treaty text.
Article 7
Business Profits
Reserves business profits to the residence state absent a permanent establishment.
Business-profits relief under the UK-Denmark treaty is the practical operating rule for cross-border services and trading enterprises. Attribution rules in the article apply once a PE exists in the source country.
Article 10
Dividends
Provides reduced and zero-percent rates for qualifying cross-border dividends.
The UK-Denmark treaty dividend article has been substantially shaped by the 1991 and 1996 protocols. Qualifying parent-subsidiary cases can achieve a zero rate, while the 15 percent rate applies more broadly.
Article 11
Interest
Generally removes source-country withholding on qualifying interest.
Interest payments between the UK and Denmark commonly arise in intercompany financing. The zero rate is the headline and the beneficial-ownership tests must still be satisfied.
Article 12
Royalties
Generally removes source-country withholding on qualifying royalties.
The royalty article applies a zero rate to qualifying payments across the major categories. The article-level definition governs characterization questions for mixed contracts.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–GB treaty
- TreatyGB–CA treaty
- TreatyGB–AU treaty
- TreatyGB–DE treaty
- TreatyGB–FR treaty
- TreatyGB–JP treaty
- TreatyGB–IE treaty
- TreatyGB–NL treaty
Primary sources
- HMRC Denmark tax treaties pageVerified 2026-05-20
- Danish Customs and Tax Administration (Skat) treaty listVerified 2026-05-20
- OECD MLI signatories and partiesVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.