The amending protocol to the 1979 income and capital tax treaty between Denmark and Greenland came into force on 19 December 2024.
The new protocol incorporates the DBO of the OECD’s BEPS minimum standards (Base Erosion and Profit Shifting), which Denmark and Greenland are obliged to implement; introduces a provision not to impose withholding tax on dividends to recognised pension institutions or to banking institutions’ pool schemes; and inserts a renegotiation clause for taxation of dividends in the event of significant changes to Greenland’s corporate tax legislation.
Earlier, Denmark and Greenland signed an amending protocol to update the Denmark-Greenland Income Tax and Mutual Assistance Treaty (1979) on 19 August 2024.
The treaty has been previously amended by protocols in 1983, 1986, 1990, 1995, 1997, 1998, 2000, 2004, and 2012. The latest signing took place during a visit by Jeppe Bruus Christensen, Danish Minister of Taxation, to Greenland from 18 to 21 August 2024.
