Denmark has notified the Depositary of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“MLI”) of its withdrawal of a reservation made under Article 28(2)(a) of the MLI. 

The reservation reads:

“2. Part VI (Arbitration) of the Convention shall apply to a tax case only insofar the Parties agree that

  1. the Chair of the arbitration panel shall be a judge, and
  2. Denmark shall be permitted to publish abstracts of decisions made by the arbitration panel.”

With the withdrawal of the reservation made by Denmark as communicated by the Depositary on 30 June 2021, paragraph 12 of Article 25A of the Singapore-Denmark DTA is deleted with effect from 30 June 2021. Please refer to the Income Tax (Singapore-Denmark)(Avoidance of Double Taxation Agreement)(Modifications to Implement Multilateral Instrument)(Amendment) Order 2021 made on 17 November 2021 for details. For informational purposes, a note has been added to paragraph 12 of Article 25A of the Singapore-Denmark DTA, which may be accessed from the List of DTAs, Limited DTAs and EOI Arrangements page.