62 STAT.] DENMA.RK -DOUBLE TAXATION-MAY 6, 1948 former State if such resident or corporation or other entity is not engaged in trade or business in such former State. Article XIII Students or apprentices, citizens of one of the contracting States, residing in the other contracting State exclusively for purposes of study or for acquiring business experience, shall not be taxable in the latter State in respect of remittances (other than their own income) received by them from abroad for the purposes of their maintenance or studies. Article XIV A professor or teacher, a resident of one of the contracting States, who temporarily visits the territory of the other contracting State for the purpose of teaching for a period not exceeding two years at a university, college, school or other educational institution in the other contracting State, shall be exempted in such other contracting State from tax on his remuneration for such teaching for such period. Article XV It is agreed that double taxation shall be avoided in the following manner: (a) The United States in determining the income taxes, in- cluding surtaxes, of its citizens, residents or corporations may, regardless of any other provision of this Convention, include in the basis upon which such taxes are imposed all items of income taxable under the revenue laws of the United States as if this convention had not come into effect. The United States shall, however, subject to the provisions of section 131, Internal Revenue Code, deduct from its taxes the amount of Danish taxes specified in Article I of this Convention. (b) Denmark, in determining its taxes specified in Article I of this Convention, may, regardless of any other provision of this Convention, include in the basis upon which such taxes are imposed all items of income subject to such taxes under the taxation laws of Denmark. Denmark shall, however, deduct from the taxes so calculated the United States tax on income coming within the pro- visions of Articles III, IX, X (1), XIII and XIV of this Convention and on earned income earned within the United States, but in an amount not exceeding that proportion of the Danish taxes which such income bears to the entire income subject to tax by Denmark. Denmark will also allow as a deduction from its taxes an amount equal to 15 percent (five percent in the case of dividends covered by Article VI (3)) of the gross amount of dividends (reduced by the United States tax applicable to such dividends) from sources within the United States. Article XVI (1) The citizens of one of the contracting States shall not, while resident in the other contracting State, be subjected therein to other 1735 Students or appren- tices. Teachers. Manner for avoiding double taxation. 53 Stat. 56 . 26U. .C.§131. Ante, p. 1730. Ante, p. 1732 et seq. Ante, p. 733 Taes on citizens of other contracting State.
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