New Danish Anti-Avoidance Rules On Withholding Tax On Dividends

On 3 October 2012, the Danish Ministry of Taxation presented a bill containing - inter alia - anti-avoidance rules regarding withholding tax on dividends. The new rules could have negative consequences in particular for multinationals and others with Danish holding companies.

Withholding tax on dividends - the beneficial owner campaign

Under the Danish holding company regime dividends distributed by a Danish company to a foreign parent company (a company holding at least 10% of the shares in the Danish company) are as a starting point exempt from Danish withholding tax, provided that the foreign parent company is resident within the EU or in a jurisdiction that has entered into a double tax treaty with Denmark.