Appendix 1

the Law on the amendment of the Act on the conclusion of Protocols on the amendment of the double taxation agreements between Denmark and Belgium, Luxembourg, Singapore and Austria respectively

(Implementation of Protocol to Amendment of the double taxation agreement between Denmark and Luxembourg)

We, by God's grace, the Queen of the Danes, do our thing.

The parliament has adopted the following law, and we know that the following law has been approved by Parliament's consent :

§ 1

Law no. 1131 of 4. In December 2009 on the conclusion of Protocols on alteration of the double taxation agreements between Denmark and Belgium, Luxembourg, Singapore and Austria respectively, the following changes shall be made :

1. After Section 2 is inserted :

" § 2 a. Protocol of 9. July, 2013, to amend the Agreement of 17. In November 1980 between Denmark and Luxembourg, the avoidance of double taxation and the laying down of provisions for mutual administrative assistance as regards income and property taxes, as amended by the Protocol of 4. In June 2009 can be drawn on behalf of Denmark. The Minutes are listed in Annex 2 (a) to this Act.

Paragraph 2. The Protocol shall enter into force and apply in Denmark following the provisions of Article 4 of the Protocol. ` ;

2. As Annex 2 A the following Annex 1 is added to this law.

§ 2

Paragraph 1. The law shall enter into force at the time of the Protocol, as mentioned in Section 1, no. 1, pursuant to Article 4, shall enter into force. The Tax Minister shall announce the date of entry into force of the law.

Paragraph 2. For people like the 9th. July 2013 was the resident of Luxembourg and on that date received a pension from Denmark covered by Article 18 (1). Article 21 (1) or Article 21 (1). 1, in the Convention of 17. In November 1980 between Denmark and Luxembourg, the avoidance of double taxation and the laying down of provisions for mutual administrative assistance as regards income and property taxes, as amended by the Protocol of 4. In June 2009, pensions may be eligible for pensions covered by Article 18 (1). 2, in the Agreement as amended by the Protocol of 9. July, 2013, only tax in Luxembourg. 1. Act. shall be applicable only as long as the person concerned remains the home of Luxembourg.

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Appendix 1

' Annex 2 a

Protocol

to amend the Agreement between the Government of the Kingdom of Denmark and the Government of the Grand Duchy of Luxembourg for the avoidance of double taxation and the determination of rules for mutual administrative assistance in respect of income-and asset taxes,

The Government of the Kingdom of Denmark and the Government of the Grand Duchy of Luxembourg,

which wish to conclude a protocol to amend the Agreement between the Government of the Kingdom of Denmark and the Government of the Grand Duchy of Luxembourg for the avoidance of double taxation and the laying down of provisions for mutual administrative assistance for so that : as regards income and property taxes and the Ending Protocol, signed in Luxembourg on 17. November 1980, ("Agreement of Agreement") , as amended by the Protocol, signed in Luxembourg on 4. June 2009,

agree on the following :

ARTICLE 1

Article 18 of the Agreement (pensions and public social security benefits) is hereby repealed and replaced by the following :

' Article 18

Pensions, social security services and similar payments

1. Payments as a natural person resident in a Contracting Government shall receive, in accordance with the social security law of the other Contracting Government or by any other scheme from the funds provided for by this other State or of any other Member State, The relevant political subdivision or local authority may only be taxed in this other state.

2. Unless the provisions of paragraphs 1 and 3 of this Article and paragraph 2 of Article 19 provide otherwise, pensions may and other similar remuneration derived from a Contracting Government and be paid to a person resident in the other ; Contracting Governments, whether they are to be used in the past or not, are subject to taxation only in this other state. However, pensions and other similar charges may be taxed in the former state if :

a contribution paid by the person entitled to the pension scheme was deduced from the taxable income of the person concerned in the first state in accordance with the law of this State ; or

b. contributions paid by an employer were not taxable income for the person entitled to the first state in accordance with the law of this State.

3. Pensions and other similar charges (including one-time charges) originating from a Contracting Government and paid to a person resident in the other Contracting Government may only be taxed in the former state, provided that such charges are made ; payments made from contributions paid to or deducted from the payment of a pension scheme by the person entitled or on its behalf, and these contributions, provisions or pensions or other similar charges have been ; shall be subject to the taxation of the first-mentioned state in accordance with the ordinal rules laid down in its tax. `

ARTICLE 2

A protocol shall be attached to the Agreement with the following provision :

" Protocol

The Government of the Kingdom of Denmark and the Government of the Grand Duchy of Luxembourg,

are-at the signing of the Protocol to Amendment of the Agreement between the Government of the Kingdom of Denmark and the Government of the Grand Duchy of Luxembourg, the avoidance of double taxation and the establishment of rules on mutual administrative assistance ; in the case of income and property taxes and the Ending Protocol, signed in Luxembourg on 17. November 1980, ("Agreement of Agreement") , as amended by the Protocol, signed in Luxembourg on 4. June 2009-agreed on the following provision, which shall form an integral part of the Agreement :

With regard to paragraph 1 of Article 18 :

It is agreed that payments received after any other scheme from the funds provided for by a Contracting Government shall include, in particular, unemployment benefits, sickness benefits, maternity benefits and training aid. `

ARTICLE 3

In the case of a natural person who :

1. was the home of Luxembourg on the day of the signing of this Protocol, and

On this day, pensions were received which could only be taxed in Luxembourg in accordance with paragraph 1 of Article 18 of the Agreement,

such pensions may, notwithstanding the provisions of Article 1 of this Protocol, be taxed only in Luxembourg as long as the natural person remains resident in Luxembourg.

ARTICLE 4

1. Contracting Governments must inform each other of the diplomatic means when the constitutional conditions of this Protocol have been entered into force.

The Protocol shall enter into force on the date of the last of the information referred to in paragraph 1 of paragraph 1 and its provisions shall have effect on taxes on the income resulting from the entry into force immediately after the year of entry into force of the Protocol. and the following revenue.

In the case of the undersigned, duly authorised by their respective governments, they shall be signatories to this Protocol.

Done at Brussels, 9. July 2013, in two copies in French and Danish, which two texts are equally valid.