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The Government of the Kingdom of Denmark and the Government of the Italian Republic,

Desiring to conclude a Convention to avoid double taxation with respect to taxes on income and on capital and to prevent fiscal evasion,

Have agreed upon the following measures:

This Convention shall apply to persons who are residents of one or both of the Contracting States.

1. This Convention shall apply to taxes on income and on capital imposed on behalf of a Contracting State or of its political or administrative subdivisions or local authorities, irrespective of the manner in which they are levied.

2. There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages and salaries paid by enterprises, as well as taxes on capital appreciation.

3. The existing taxes to which the Convention shall apply are, in particular:

(a) In the case of Denmark:

(1) The income tax to the state (indkomstskatten til staten);

(2) The municipal income tax (den kommunale indkomstskat);

(3) The income tax to the county municipalities (den amtskommunale indkomstskat);

(4) The old age pension contributions (folkepensionsbidragene);

(5) The seamen's tax (somandsskatten);

(6) The special income tax (den serlige indkomstskat);

(7) The church tax (kirkeskatten);

(8) The tax on dividends (udbytteskatten);

(9) The contribution to the sickness per diem fund (bidrag til dagpengefonden) and

(10) The capital tax to the state (formueskatten til staten)

(hereinafter referred to as "Danish tax").

Vol. 1332. 1-22348

1. ↑ Came into force on 25 March 1983 by the exchange of an instrument of ratification by Italy and an instrument of approval by Denmark, which took place at Copenhagen, in accordance with article 31 (2).