in Singapore. Where a resident of Singapore derives income from Denmark which, in accordance with the provisions of this Agreement, may be taxed in Denmark, Singapore shall, subject to its laws regarding the allowance as a credit against Singapore tax of tax payable in any country other than Singapore, allow the Danish tax paid, whether directly or by deduction, as a credit against the Singapore tax payable on the income of that resident. Where such income is a dividend paid by a company which is a resident of Denmark to a resident of Singapore which is a company owning directly or indirectly not less than 10 percent of the share capital of the first-mentioned company, the credit shall take into account the Danish tax paid by that company on the portion of its profits out of which the dividend is paid.
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