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Denmark: Double Tax Treaties

Table Of Treaty Rates

Provided by TreatyPro
Denmark


Jurisdiction Status Dividends Interest Royalties Notes
           
Defaults 15% where the payee is a company holding directly less than 10% of the paying company's capital 27% 0% where the payee is a company holding more than 50% of the paying company's capital or voting stock 25% 0% for copyright, news or equipment royalties 25%
           
Argentina Effective January 1, 1998 10% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan guaranteed for at least three years by the government or the central bank, or on sales on credit of equipment or merchandise 12% 3% for news royalties 5% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 10% for the use of any equipment, patent, trademark, design or model, plan, secret formula or process, or information concerning industrial or scientific experience 15%
Armenia Effective January 1, 1988 0% 0% 0% Denmark continues to apply the USSR treaty (Armenia does not).
Australia Effective January 1, 1982 15% 10% 10%
Austria Effective January 1, 2009 0% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0%
Bangladesh Effective January 1, 1997 10% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan financed, guaranteed or insured by the government or the central bank, or on financing in connection with the selling of equipment or the construction of industrial, commercial or scientific installations, as well as with public works 10% 10%
Belarus Effective January 1, 1988 0% 0% 0% The USSR treaty continues to apply.
Belgium Effective January 1, 1971 Protocol effective January 1, 2004 0% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% when paid on commercial debt-claims resulting from payments for goods, merchandise or services, or on a bank deposit not represented by bearer instruments, or on current accounts or advances between banks 10% 0%
Brazil Effective January 1, 1975 25% 0% when paid to the government, or on government bonds, securities or debentures 15% 15% 25% for trademark royalties
Bulgaria Effective January 1, 1990 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0%
Canada Effective January 1, 1999 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or a pension fund, or between the central banks, or on a loan or credit financed, guaranteed or insured by a specified institution, or on sales on credit of equipment, merchandise or services, or as a penalty charge for late payments 10% 0% for the use of any literary, artistic, dramatic or musical copyright (excluding broadcasting royalties), computer software or patent, or information concerning industrial, commercial or scientific experience (excluding a rental or franchise agreement) 10%
Chile Effective January 1, 2005 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% 15% 5% for equipment royalties 15%
China Effective January 1, 2013 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 10% 0% when paid to the government or the central bank, or on a loan or credit financed, guaranteed or insured by the government or the central bank 10% 7% for equipment royalties 10%
Croatia Effective January 1, 2010 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital for 12 months before the dividend is declared, or a pension fund 10% 5% 10%
Cyprus Effective January 1, 2012 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital for 12 months before payment of the dividend, the government, the central bank or a pension fund 15% 0% 0%
Czech Republic Effective January 1, 2013 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital, or a pension fund 15% 0% 0% for copyright or broadcasting royalties 10%
Egypt Effective June 1, 1990 15% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 20% 15% 20%
Estonia Effective January 1, 1994 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan guaranteed by the government or the central bank, or on sales on credit of equipment or merchandise 10% 5% for equipment royalties 10%
Faroe Islands Effective January 1, 1998 0% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0%
Finland Effective January 1, 1998 0% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0%
Georgia Effective January 1, 2009 0% where the payee is a company holding at least 50% of the paying company's capital with a minimum investment of EUR2m or equivalent, the government or the central bank 5% where the payee is a company holding at least 10% of the paying company's capital with a minimum investment of EUR100,000 or equivalent 10% 0% 0%
Germany Effective January 1, 1997 5% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0%
Ghana Signed March 20, 2014 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital, the government, the central bank or a pension fund 15% 0% when paid to the government, the central bank or a pension fund, or by the government or the central bank, or on a loan financed, guaranteed or insured by the government, or on sales on credit of equipment or merchandise 8% 8% Not yet in force. Default rates apply.
Greece Effective January 1, 1993 18% 8% 5%
Greenland Effective January 1, 1981 0% 0% 10%
Hungary Effective January 1, 2013 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital for 12 months before payment of the dividend, or a pension fund 15% 0% 0%
Iceland Effective January 1, 1998 0% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0%
India Effective January 1, 1990 15% where the payee is a company holding at least 25% of the paying company's capital 25% 0% when paid to the government or the central bank, or on a loan or credit financed, guaranteed or insured by the government or the central bank 10% when paid on a bank loan 15% 20%
Indonesia Effective January 1, 1987 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 20% 0% when paid to the government or the central bank 10% 15%
Ireland Effective January 1, 1994 0% 15% where the payee is a company (excluding a partnership) holding directly less than 25% of the paying company's capital 0% 0%
Israel Effective January 1, 2013 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital for 12 months before the dividend is declared, the government, the central bank or a pension fund 10% 0% when paid to a pension fund, or on corporate bonds traded on a stock market, or on a loan or credit financed by the government or the central bank, or on a loan or credit guaranteed or insured by a government institution financing international trade transactions 5% 0%
Italy Effective January 1, 2004 0% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital for 12 months before the dividend is declared 15% 0% when paid by the government, or on a loan financed, guaranteed or insured by the government or the central bank, or on sales on credit of equipment or goods 10% 0% for copyright royalties (excluding broadcasting royalties) 5%
Jamaica Effective December 1, 1991 10% where the payee is a company (excluding a partnership) holding at least 25% of either the paying company's capital or its voting stock 15% 0% when paid to the government or the central bank, or on a loan or credit guaranteed or insured by the government or the central bank 12.5% 10%
Japan Effective January 1, 1969 10% where the payee is a company holding at least 25% of the paying company's voting stock for 12 months before the end of the distribution's accounting period 15% 10% 10%
Kenya Effective January 1, 1972 20% where the payee is a company holding at least 25% of the paying company's voting stock for six months before payment of the dividend 27% (3) 0% when paid to the government or the central bank 20% 20%
Korea, South Effective January 1, 1979 15% 0% when paid to or by the government or the central bank 15% 10% for industrial investment 15%
Kuwait Effective January 1, 2010 0% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital for 12 months before payment of the dividend, the government or the central bank 5% when paid to a pension fund 15% 0% 10%
Kyrgyzstan Effective January 1, 1988 0% 0% 0% The USSR treaty continues to apply.
Latvia Effective January 1, 1994 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan guaranteed by the government or the central bank, or on sales on credit of equipment or merchandise 10% 5% for equipment royalties 10%
Lithuania Effective January 1, 1994 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan guaranteed by the government or the central bank, or on sales on credit of equipment or merchandise 10% 5% for equipment royalties 10%
Luxembourg Effective January 1, 1979 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0%
Macedonia Effective January 1, 2001 0% when paid to a pension fund 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital for 12 months before the dividend is declared 15% 0% 10%
Malaysia Effective April 1, 1968 Protocol effective January 1, 2006 0% 0% 10%
Malta Effective January 1, 1999 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital for 12 months before the dividend is declared 15% 0% 0%
Mexico Effective January 1, 1998 0% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to or by the government, or to a pension fund, or on a loan or credit financed, guaranteed or insured for at least three years by a specified institution 5% when paid to a bank 15% 10%
Morocco Effective January 1, 1992 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 25% 0% when paid on a loan or credit financed by one government and paid to the other 10% 10%
Netherlands Effective January 1, 1999 0% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0%
New Zealand Effective January 1, 1981 15% 10% 10%
Norway Effective January 1, 1998 0% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0%
Pakistan Effective January 1, 1988 15% 0% when paid to the government or the central bank 15% 15%
Philippines Effective January 1, 1997 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid on a loan financed, guaranteed or insured by the government or the central bank 10% 15%
Poland Effective January 1, 2003 0% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital for 12 months before the dividend is declared 5% when paid to a pension fund 15% 0% when paid to the government, or on government bonds or debentures, or on a loan financed, guaranteed or insured by the government, or on sales on credit of equipment 5% 5%
Portugal Effective January 1, 2003 10% 0% when paid to or by the government or the central bank 10% 10%
Romania Effective January 1, 1974 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 10% 10%
Russia Effective January 1, 1998 10% 0% 0%
Montenegro Effective January 1, 1983 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's voting stock 15% 0% 10% The Yugoslavia treaty continues to apply.
Singapore Effective January 1, 2001 0% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital for 12 months before the dividend is declared 5% when paid to a pension fund 10% 0% when paid on a loan financed, guaranteed or insured by the government 10% 10%
Slovakia Effective January 1, 1983 15% 0% 0% for copyright or broadcasting royalties 5% The Czechoslovakia treaty continues to apply.
Slovenia Effective January 1, 2003 0% where the payee is a company holding directly at least 25% of the paying company's capital for 12 months before the dividend is declared 5% when paid to a pension fund 15% 5% 5%
South Africa Effective January 1, 1996 5% where the payee is a company holding at least 25% of the paying company's capital 15% 0% 0%
Sri Lanka Effective January 1, 1980 15% 0% when paid to or by the government 10% 10%
Sweden Effective January 1, 1998 0% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0%
Switzerland Effective January 1, 1975 Protocol effective January 1, 2011 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital, or a pension fund 15% 0% 0%
Taiwan Effective January 1, 2006 10% 0% when paid to the government or the central bank 10% 10%
Tanzania Effective January 1, 1977 15% 12.50% 20%
Thailand Effective January 1, 2000 10% 0% when paid on a loan financed, guaranteed or insured by the government or the central bank 10% when paid to a financial institution or insurance company 15% 5% for copyright royalties (excluding broadcasting royalties) 15%
Trinidad and Tobago Effective January 1, 1966 10% where the payee is a company holding at least 25% of the paying company's voting stock 20% 15% 0% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 15%
Tunisia Effective January 1, 1982 15% 12% 10%
Turkey Effective January 1, 1991 15% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 20% 0% when paid to the government or the central bank 15% 10%
Uganda Effective January 1, 2002 0% when paid to the government or the central bank 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank 10% 10%
Ukraine Effective January 1, 1997 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan guaranteed by the government or the central bank, or on sales on credit of equipment 10% 0% for copyright or broadcasting royalties, or the use of any patent, trademark, design, model or plan 10%
United Kingdom Effective January 1, 1978 Protocol effective January 1, 1998 0% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% 0%
United States Effective May 1, 2000 Protocol effective February 1, 2008 0% where the payee is a company holding at least 80% of the paying company's voting stock for 12 months before the dividend is declared, the government or a pension fund 5% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0% Separate dividend withholding tax rules apply to REITs.
Venezuela Effective January 1, 2002 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital for 12 months before the dividend is declared 15% 0% when paid to or by the government or the central bank, or on a loan financed or guaranteed by a financial institution to promote exports and development 5% 10%
Vietnam Effective January 1, 1997 5% where the payee is a company (excluding a partnership) holding directly at least 70% of the paying company's capital, or has invested a minimum of USD12m or equivalent 10% where the payee is a company (excluding a partnership) holding at least 25% but less than 70% of the paying company's capital 15% 0% when paid to the government or the central bank 10% 5% for the use of any patent, design or model, plan, secret formula or process, equipment or information concerning industrial or scientific experience 15%
Zambia Effective January 1, 1972 15% 0% when paid to the government 10% 15%
Serbia Effective January 1, 2010 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank 10% 10%

Footnotes

  1. In the case of European Union countries, the EC Parent-Subsidiary Directive can reduce dividend withholding tax to 0%, subject to certain conditions.
  2. In the case of European Union countries, the EC Interest and Royalties Directive can reduce interest and royalties withholding tax to 0%, subject to certain conditions.
  3. The treaty specifies a different rate but the default rate is lower and would therefore apply.
  4. PLEASE NOTE: This table was last updated February 2015

 

 

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