In 2008, the Danish tax authorities terminated this agreement, which means that from 2008, when a Danish pensioner moved/moved to France, his pension allowances were or will be taxed in both countries: France and Denmark! (double taxation). You can imagine that it deterred Danish pensioners from moving to France. The new double taxation convention is expected to enter into force on 1 January 2021. In its denunciation communication, the Danish Government attributed the reason for its decision to the deadlock in the negotiations for a new agreement, in particular as regards the taxation of pension income. Denmark insisted on withholding tax because it has a scheme in which pension premiums are deductible and the pension structure is exempt, while only pension rights received are taxable. – The Danish supplier is subject in France to a higher tax than he would have suffered if he had been established in France. BulgariaThe Bulgarian tax convention and international conventions In order to avoid double taxation of income, Denmark has concluded DTT with a large number of countries. All tax treaties contain rules for the exchange of tax information and specific EU rules also apply. Double taxation can also occur with regard to inheritance tax. To remedy this situation, Denmark has concluded agreements in this regard with the other Scandinavian countries, Germany, Italy, Switzerland and the United States. Countries with which Denmark currently has SDRs and in which the convention contains a remuneration clause: this is a change from the usual structure of double taxation treaties, under which the country of residence reduces its taxes in order to avoid double taxation.
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