Denmark Tax Agency Clarifies Taxation of Income Earned on Fishing Vessel Under 1996 Nordic DTA

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The Danish Customs and Tax Administration March 17 posted online City Court Decision No. SKM2023.125.BR, clarifying the taxation of income earned on a fishing vessel under the 1996 Nordic DTA. The taxpayer was resident and domiciled in Denmark and fully taxable there. He worked on a foreign ship registered as a fishing vessel. The ship sailed in international waters and anchored in a second foreign country part of the year. Denmark taxed his income, and the taxpayer protested. The City Court ruled for the Tax Agency, finding that: 1) Denmark had the right to tax under the DTA as the …

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