Denmark Tax Agency Clarifies Tax Residence Under DTA With Germany

The Danish Customs and Tax Administration March 22 posted online Tax Board Binding Answer No. SKM2021.158.SR, clarifying tax residence under the 1995 DTA with Germany. A taxpayer spends his free time in Denmark with his family, and his work time in Germany as a director and co-owner of a company. The taxpayer, subject to full tax liability in both countries, inquired as to his tax residence status under the 1995 DTA. The tax board upheld the tax agency’s opinion, explaining that: 1) the taxpayer’s center of vital interests can’t be determined conclusively as his personal relations are in Denmark but ...