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Article III of the Protocol amends subparagraph b) of paragraph 2 of Article 19

U.S. Income Tax Treaty — denmark tax treaty documents: denmarkte07.pdf · 2026-10-03 edition · updated 2026-10-04 · United States

(Government Service) of the Convention to correct a drafting error. Paragraph 2 (a) provides a general rule that a pension paid from public funds of a Contracting State or a political subdivision or local authority thereof to an individual in respect of services rendered to that State or subdivision or authority in the discharge of governmental functions is taxable only in that State. Paragraph 2(b) provides an exception under which the pension is taxable only in the other State if the individual is a resident of and a national of that other State. Before this amendment, paragraph 2(b) incorrectly referred to pensions paid to “a resident or a national” rather than pensions paid to “a resident and a national.”

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