Non-resident entities operating inthe Greenland through a permanent establishment ('PE') are subject to tax on income sourced from the Greenland.

Non-resident entities deriving income from the source in the Greenland without a PE are subject to withholding tax ('WHT') on their income (See sec. 8.2.2. below for tax rates). However, capital gains are not subject to WHT in Greenland.

Oil and Mineral Sector

Non-resident companies deriving income from operations of prospecting and exploration of oil, gas and minerals are subject to tax in Greenland regardless of the existence of a PE, including activities of subcontractors and service providers serving the extracting industries.

However, license for exploitation of mineral resources is granted only to resident public limited companies. In case a PE of a foreign company is engaged in exploitation of minerals in the country then the PE is required to be converted into a public limited company and must obtain a license for the same. Such conversion or transfer of business is considered as a taxable transaction, subject to certain conditions (See Sec. 11.).