Denmark has extended the limitation period for claiming a refund of dividend tax from 3 years to 5 years following a June 2026 Danish Supreme Court ruling, with relevant rejected cases to be automatically reopened by the end of 2026.
The Danish Tax Agency has extended the limitation period for claiming a refund of Danish dividend tax from 3 years to 5 years following a June 2026 decision by the Danish Supreme Court. The agency has updated its guidance on claiming a refund of Danish dividend tax and said it will automatically reopen relevant cases that were rejected under the former 3-year limitation period.
The Danish Tax Agency expects to reopen all relevant cases before the end of 2026. Claimants do not need to submit a new request for their cases to be reopened.
5-year limitation period
Under the revised rules, a claim for a refund of dividend tax must be submitted within 5 years from the date the dividend tax was withheld.
The Danish Supreme Court ruled in June 2026 that the previous 3-year limitation period applied by the Danish Tax Agency was incorrect and that the applicable limitation period is 5 years.
Since 2016, the Danish Tax Agency has rejected claims where the 3-year limitation period had expired.
Cases subject to reopening
The Danish Tax Agency will reopen relevant cases where the claim relates to dividend tax withheld after 11 June 2021 and the claim was fully or partially rejected because it was submitted outside the former 3-year limitation period.
Cases will also be reopened where a claim for a refund of dividend tax was submitted but remains undecided.
In addition, the reopening applies where a claim was submitted within the 5-year limitation period and the Danish Tax Agency made its decision after 11 June 2025.
A request for reopening may also qualify where a claim for a refund of dividend tax had already been decided within the limitation period and was put on hold at the claimant’s request.
Assessment under revised rules
The reopened claims will be assessed under the new 5-year limitation period and the ordinary rules on reopening.
The Danish Tax Agency said the automatic reopening process means affected claimants do not need to take any action to have their cases reconsidered.
