Through his/her signature, the pension holder accepts that disbursements from his/her pension plan under PBL will be subject to taxation in Denmark - to the extent that Denmark could have taxed the disbursements because the bank or pension provider had been domiciled in Denmark.

The fact that the pension holder accepts being taxed on disbursements from his/her pension plan in Denmark means that, if the pension holder has taken out a pension plan with a bank or pension provider in a country with which Denmark has entered into a double taxation treaty concerning taxation by the country of source, and if the pension holder has had this approved under Section 15 C of PBL, and if the pension holder subsequently stays in Denmark when he/she attains pension age, the relevant country is able to tax the disbursements as the country of source in accordance with the double taxation treaty.

Denmark also taxes the disbursements in accordance with the declaration. However, Denmark allows for credit relief for the foreign tax under Section 33(1), cf. Section 15 C(4), Item 2 of the Danish Tax Assessment Act (Ligningsloven). Tax is thus payable to Denmark with relief for tax at source already paid to the country of source.

If, at the time of pensioning, the pension holder moves to the country in which the pension plan was taken out, this country is able to tax the disbursements from the pension holder's pension plan both as the country of source and as the country of residence, while Denmark is able to tax the disbursements in accordance with the pension holder's declaration.

It is not possible to have the Danish tax reduced by the tax paid in this other country. Instead, the other country should, as the country of residence for the pension holder, apply this country's internal relief rules in relation to the Danish tax paid.