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Germany - Denmark Tax Treaty (as amended by 2020 protocol) — Orbitax Tax Hub

CHAPTER I - GENERAL PROVISIONS
CHAPTER II - TAXATION OF INCOME AND CAPITAL
CHAPTER III - TAXATION OF ESTATES, INHERITANCES AND DONATIONS
CHAPTER IV - MUTUAL ASSISTANCE IN MATTERS OF TAXATION
CHAPTER V - TAXPAYER'S PROTECTION AND MUTUAL AGREEMENT PROCEDURE
CHAPTER VI - SPECIAL PROVISIONS
Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 46

Refund of Withholding Tax

(1) If in a Contracting State taxes are deducted at source from dividends, interest, royalties or other items of income, the right to deduct the tax at the rate provided for by the domestic law of that State, shall not be affected by this Convention.

(2) Taxes deducted at source shall be repaid on application, if the levying of such taxes is restricted by this Convention.

(3) The period within which the application for repayment must be made is four years after expiry of the calendar year in which the dividends, interest, royalties or other items of income have been received.

(4) The Contracting State in which the income originates may demand an official attestation from the Contracting State in which the taxpayer is resident that he fulfils the conditions for unrestricted tax liability in that State.

(5) The competent authorities of the Contracting States shall implement the above provisions by mutual agreement in accordance with Article 43.

(6) The competent authorities of the Contracting States may establish by mutual agreement other procedures for the implementation of the tax measures provided for in this Convention.