The Danish Ministry of Taxation approved the Bill on 14 December 2012 relating anti-avoidance rules about withholding tax on dividends.
The key points of the Bill are summarized below:
Under the Danish holding company rule dividends (resident to foreign) are exempt from Danish withholding tax if the foreign parent company is resident within the EU or in a jurisdiction that has entered into a double tax treaty with Denmark.
Also under this Bill the exemption from Danish withholding tax on dividends paid by a Danish company to a foreign parent company shall no longer apply if those dividends has received from a foreign subsidiary and the Danish company is not the beneficial owner of the dividends received from the foreign subsidiary.
