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DT5910 - Double Taxation Relief Manual - HMRC internal manual

DT5910 - Double Taxation Relief Manual: Guidance by country: Denmark: Notes You should check the other guidance available on GOV.UK from HMRC as Brexit updates to those pages are being prioritised before manuals. Hired out employees (Article 15) ‘Hired out’ employees are those whose services are hired out by their employer to another employer who effectively directs and controls the activities of the employee, the first employer having no responsibility for carrying out the work on which the employee is engaged. Article 15(3) of the convention, which was introduced by the 1991 amending convention, denies the employee any exemption from tax in the country in which they are working they might otherwise have obtained under Article 15(2).

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