Denmark: Domestic Corporate Taxation
Withholding Taxes on Outgoing Dividends
The standard rate of withholding taxes levied in Denmark on outgoing dividends is 15% (reduced from 28% on April 1, 2008), provided that the recipient holds less than 10% of the shares in the distributing company and there is a tax agreement in place between Denmark and the state where the non-resident is located (e.g. a double tax treaty of other administrative agreement). This rate can be reduced by both the provisions of a double taxation treaty and by the provisions of the EU Parent-Subsidiary Directive. Alternatively where the dividends are remitted by an intermediate Danish Holding Company to a foreign parent corporation no withholding taxes are deducted provided that there is a double tax treaty in force between the two countries, and:
- The foreign parent corporation holds a minimum of 10% of the shares in the intermediate Danish holding company. (N.B. If the shareholding is less than 10% then the double tax treaty rate will apply); and
- The parent corporation is non-resident.