Article 15 Dependent Personal Services 1.Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in the other Contracting State. 2.Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned Contracting State if: (a)the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in the calender year concerned, and (b)the remuneration is paid by, or on behalf of, an employer who is not a resident of that other Contracting State, and (c)the remuneration is not borne by a permanent establishment or a fixed base which the employer has in that other Contracting State. 3.Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic may be taxed in the Contracting State in which the place of effective management of the enterprise situated. Article 16 Directors' Fees Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State. Article 17 Artistes and Athletes 1.Notwithstanding the provisions of Articles 14 and 15, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as an athlete, from his personal activities as such exercised in the other Contracting State, may be taxed in that other Contracting State. 2.Where income in respect of personal activities exercised by an entertainer or an athlete in his capacity as such, accrues not to the entertainer or athlete himself but to another person, that income may, notwithstanding the provisions of Articles 7, 14 and 15, be taxed in the Contracting State in which the activities of the entertainer or athlete are exercised. 3.Notwithstanding the provisions of paragraphs 1 and 2, income derived by entertainers or athletes who are residents of a Contracting State from the activities exercised in the other Contracting State under a plan of cultural exchange between the Governments of both Contracting State, shall be exempted from tax in other Contracting State. Article 18 Pensions and Social Security Payments 1.Subject to the provisions of paragraph 2 of Article 19, pensions and other similar remuneration paid to a resident of a Contracting State in consideration of past employment shall be taxable only in that Contracting State. 2.Notwithstanding the provisions of paragraph 1, pensions paid and other similar payments made under a public welfare scheme of the social security system by the Government of a Contracting State or a local authority thereof shall be taxable only in that Contracting State. Article 19 remuneration and Pensions in respect of Government Service 1.(a)Remuneration, other than a pension, paid by the Government of a Contracting State or a local authority thereof to an individual in respect of services rendered to the Government of that Contracting State or a local authority thereof, in the discharge of functions of a governmental nature shall be taxable only in that Contracting State. (b)However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that other Contracting State and the individual is a resident of that other who: (i)is a national of that other Contracting State; or (ii)did not become a resident of that other Contracting State solely for the purpose of rendering the services. 2.(a) Any pension paid by, or out of funds created by the Government of a Contracting State or a local authority thereof to an individual in respect of services rendered to the Government of that Contracting State or a local authority thereof shall be taxable only in that Contracting State. (b) However, such pension shall be taxable only in the other Contracting State if the individual is a resident of, and a national of, that other Contracting State. 3.The provisions of Articles 15, 16, 17 and 18 shall apply to remuneration and pensions in respect of services rendered in connection with a business carried on by the Government of a Contracting State or a local authority thereof. Article 20 Teachers and Researchers 1.An individual who is a resident of a Contracting State at the beginning of his visit to the other Contracting State and who, at the invitation of the Government of that other Contracting State or of a university or other educational or scientific research institution situated in that other Contracting State and approved by an educational authority of that other Contracting State, is present in that other Contracting State for the primary purpose of teaching, giving lectures or engaging in research at such university or other educational or scientific research institution shall be exempt from tax by that other Contracting State on his income from personal services for teaching, giving lectures or engaging in research at such university or other educational or scientific research institution for a period not exceeding three years from the date of his arrival in that other Contracting State. Article 21 Students, Apprentices and Trainees 1.A student, business apprentice or trainee who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of his education or training shall be exempt from tax in that State on: (i) all remittances made from abroad for the purpose of his maintenance, education or training; (ii) all scholarships, grants, allowances and awards from governmental, charitable, scientific, literary or educational organisations for the purposes of his maintenance, education or training; and (iii) income from personal services performed in that Contracting State (other than any rendered by a business apprentice to the person or partnership to whom he is apprenticed, or, in the case of a trainee, other than services rendered to the person providing the training) in an amount not in excess of what is needed for the purpose of his maintenance, for any year of assessment. 2.The exemptions under paragraph 1 shall only continue for such period of time as may reasonably or customarily be required to complete the education or training undertaken but in no event shall any individual have the benefit of paragraph 1 for more than five years from the commencement of such education or training. Article 22 Other Income 1.Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Agreement shall be taxable only in that Contracting State. 2.The provisions of paragraph 1 shall not apply to income other than that from immovable property as defined in paragraph 2 of Article 6 if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the income is paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or 14, as the case may be, shall apply. 3.Notwithstanding the provisions of paragraphs 1 and 2, items of income of a resident of a Contracting State not dealt with in the foregoing Articles of this Agreement and arising in the other Contracting State may also be taxed in that other Contracting State. Article 23 Methods for Elimination of Double Taxation 1.In China double taxation shall be eliminated as follows: (a) where a resident of China derives income from Denmark, the amount of Danish tax payable in respect of that income in accordance with the provisions of this Agreement may be allowed as a credit against the Chinese tax imposed on that resident. The amount of credit, however, shall not exceed the amount of the Chinese tax computed as appropriate to that income in accordance with the taxation laws and regulations of the People's Republic of China; (b) Where the income derived from Denmark is a dividend paid by a company which is a resident of Denmark to a company which is a resident of China and which owns not less than 10 per cent of the shares of the company paying the dividend, the credit shall take into account the Danish tax payable by the company paying the dividend in respect of its income. 2.In Denmark double taxation shall be eliminated as follows: (a) Subject to the provisions of subparagraph c), where a resident of Denmark derives income which, in accordance with the provisions of this Agreement, may be taxed in China, Denmark shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in China: 　　(b) such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income which may be taxed in China; (c) where a resident of Denmark derives income which, in accordance with the provisions of this Agreement shall be taxable only in China, Denmark may include this income in the tax base, but shall allow as a deduction from the income tax that part of the income tax, which is attributable to the income derived from China; 3.For the purposes of the credit referred to in subparagraphs a) and b) of paragraph 2, Chinese tax shall be deemed to have been paid: (a) at the rate of 10 per cent in the case of dividends, to which the provisions of paragraph 2 of Article 10 apply; and (b) at the rate of 10 per cent in the case of interest to which the provisions of paragraph 2 of Article 11 apply; and (c) at the rate of 20 per cent in the case of royalties to which the provisions of paragraph 2 of Article 12 apply. 4.For the purposes of the credit referred to in paragraph 2, the term "income tax paid in China" shall be deemed to include the amount of Chinese tax which would have been paid if the Chinese tax had not been exempted, reduced or refunded in accordance with: (a) the provisions of Articles 5 and 6 of the Income Tax Law of China Concerning Joint Ventures Using Chinese and Foreign Investment and the provisions of Article 3 of the Detailed Rules and Regulations for the Implementation of the Income Tax Law of China Concerning Joint Ventures Using Chinese and Foreign Investment; (b) the provisions of Articles 4 and 5 of the Income Tax Law of China Concerning Foreign Enterprises; or (c) any other similar special incentive measures designed to promote economic development in China which may be introduced in the laws of China after the date of signature of this Agreement, and which may be agreed upon by the Governments of the Contracting State. Article 24 Non-Discrimination 1.Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of that other Contracting State in the same circumstances are or may be subjected. This provision shall, notwithstanding the provisions of Article 1, also apply to persons who are not residents of one or both of the Contracting State. 2.The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other Contracting State than the taxation levied on enterprises of that other Contracting State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. 3.Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11, or paragraph 6 of Article 12, apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned Contracting State. 4.Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned Contracting State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned Contracting State are or may be subjected. 5.The provisions of this Article shall, notwithstanding the provisions of Article 2, apply to taxes of every kind. Article 25 Mutual Agreement Procedure 1.Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement. 2.The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with this Agreement. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3.The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this Agreement. 4.The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of paragraphs 2and 3. When it seems advisable for the purpose of reaching an agreement the competent authorities of the Contracting States may meet together for an oral exchange of opinions. Article 26 Exchange of Information 1.The competent authorities of the Contracting States shall exchange such information as is necessary for carrying out the provisions of this Agreement or of the domestic laws of the Contracting States concerning taxes covered by in this Agreement, insofar as the taxation under these laws is not contrary to this Agreement, in particular for the prevention of fraud or evasion of such taxes. The exchange of information is not restricted by Article 1. Any information received by a Contracting State shall be treated as secret and shall be disclosed only to persons or authorities (including courts) involved in the assessment or collection of the taxes covered by this Agreement or the determination of appeals in relation thereto. Such persons or authorities shall use the information only for such purposes. Such information may be disclosed in public court proceedings or in judicial decisions. 2.In no case shall the provisions of paragraph 1 be construed so as to impose on a Contracting State the obligation: (a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State; (b) to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State; or (c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public). Article 27 Diplomatic Agents and Consular officers Nothing in this Agreement shall affect the fiscal privileges of diplomatic agents or consular officers under the general rules of international law or under the provisions of special agreements. Article 28 Entry into Force After mutual notifications of the completion of legal procedures necessary for the entry into force of this Agreement by the Contracting States, the Agreement shall enter into force on the date of the latter of the notifications, and its provisions shall have effect: (a) in respect of taxes withheld at the source on or after the first day of January in any year following that in which the Agreement enters into force; and (b) in respect of other taxes for the taxable year beginning on or after the first day of January in any year following that in which the Agreement enters into force. Article 29 Termination 1.This Agreement shall remain in force until terminated by a Contracting State. Either Contracting State may terminate the Agreement at any time after 5 years from the date on which the Agreement enters into force, by giving at least 6 months' prior notice of termination through diplomatic channels. In such event, the Agreement shall cease to have effect: (a) in respect of taxes withheld at the source on or after the first day of January next following the date of termination specified in the notice of termination; (b)in respect of other taxes for any taxable year beginning on or after the first day of January next following the date of termination specified in the notice of termination. IN WITNESS WHEREOF the undersigned, duly authorized thereto by their respective Governments, have signed this Agreement. DONE in duplicate at Beijing this 26th day of March, one thousand nine hundred and eighty-six year of the Christian Era, each in the Chinese, Danish and English languages, all texts being equally authoritative, except in the case of doubt, when the English text shall prevail. For the Government of the For the Government of the People's Republic of China Kingdom of Denmark