Search Legislation

The Double Taxation Relief (Taxes on Income) (Denmark) Order 1991

What Version

 Help about what version
  • Latest available (Revised)
  • Original (As made)


This is the original version (as it was originally made). This item of legislation is currently only available in its original format.


The following new provisions shall be inserted immediately after paragraph (5) of Article 11 of the Convention:

(6) The provisions of paragraph (1) of this Article shall not apply where the beneficial owner of the interest is a company other than a quoted company, unless the company shows that it is not controlled by a person, or two or more associated or connected persons together, who or any of whom would not have been entitled to relief under paragraph (1) of this Article if he had been the beneficial owner of the interest.

(7) For the purposes of paragraph (6) of this Article:

(a)a quoted company is any company the shares in which are officially quoted on a stock exchange in the Contracting State of which it is a resident, provided that the conditions for admission to such quotation, and in particular those governing the minimum value of the shares to be admitted, the transferability and the dispersion of the shares, are in conformity with the conditions set out in Schedule A to the directive of the Council of the European Communities dated 5th March 1979 No. 79/279/EEC;

(b)subject to paragraph (8) of this Article, a person or two or more associated or connected persons together shall be treated as having control of a company if, under the laws of the Contracting State in which the interest arises relating to the taxes covered by this Convention, they could be treated as having control of it for any purpose and persons shall be treated as associated or connected if, under those laws, they could be so treated for any purpose.

(8) Where an individual is treated by paragraph (7)(b) of this Article as having control of a company by reason only of the fact that he holds ordinary shares in the company carrying full voting and dividend rights, and that individual holds not more than 20 per cent of the total number of such shares in the company, the shares held by him shall be left out of account in determining whether the company is controlled by a person or two or more associated or connected persons together, provided that not more than 30 per cent of the total of such shares in the company may be left out of account in this manner.

Back to top


Print Options


Legislation is available in different versions:

Latest Available (revised):The latest available updated version of the legislation incorporating changes made by subsequent legislation and applied by our editorial team. Changes we have not yet applied to the text, can be found in the ‘Changes to Legislation’ area.

Original (As Enacted or Made):The original version of the legislation as it stood when it was enacted or made. No changes have been applied to the text.


Opening Options

Different options to open legislation in order to view more content on screen at once


More Resources

Access essential accompanying documents and information for this legislation item from this tab. Dependent on the legislation item being viewed this may include:

  • the original print PDF of the as enacted version that was used for the print copy
  • lists of changes made by and/or affecting this legislation item
  • confers power and blanket amendment details
  • all formats of all associated documents
  • correction slips
  • links to related legislation and further information resources