S.L. 123.47 Art. 2Arrangements to have effect. THE The of Malta, and the as follows: This Contracting 1. This Contracting State the manner in 2. There income, or on movable or by enterprises, 3. The (a) in (i) (ii) (iii) (iv) (b) in the 4. The taxes which are or in place of, the shall notify

It is hereby declared -

(a) that the arrangements specified in the Convention set out in the Schedule to this Order have been made with the Government of the Kingdom of Denmark with a view to affording relief from double taxation in relation to the following taxes imposed by the laws of the Kingdom of Denmark:

(i) the income tax to the State;

(ii) the income tax to the municipalities;

(iii) the income tax to the county municipalities;

(iv) taxes imposed under the Hydrocarbon Tax Act;

(b) that it is expedient that those arrangements should have effect. GOVERNMENT OF THE KINGDOM OF DENMARK AND THE GOVERNMENT OF THE REPUBLIC OF MALTA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME

Government of the Kingdom of Denmark and the Government of the Republic desiring to conclude a Convention for the Avoidance of Double Taxation Prevention of Fiscal Evasion with Respect to Taxes on Income, have agreed

ARTICLE 1

Personal Scope Convention shall apply to persons who are residents of one or both of the States.

ARTICLE 2

Taxes Covered Convention shall apply to taxes on income imposed on behalf of a or of its political subdivisions or local authorities, irrespective of which they are levied. shall be regarded as taxes on income all taxes imposed on total elements of income, including taxes on gains from the alienation of immovable property, taxes on the total amounts of wages or salaries paid as well as taxes on capital appreciation. existing taxes to which the Convention shall apply are in particular:

Denmark~ the income tax to the State (indkomsskatten tit staten); the income tax to the municipalities (den kommunale indkomstskat); the income tax to the county municipalities (den amtskommunale indkomstskat); taxes imposed under the Hydrocarbon Tax Act (skatter i henhold til kulbrinteskatteloven); (hereinafter referred to as "Danish tax"). Malta: income tax; (hereinafter referred to as "Malta tax").

Convention shall apply also to any identical or substantially similar imposed after the date of signature of the Convention in addition to, existing taxes. The competent authorities of the Contracting States each other of substantial changes which have been made in their