Main pageNewsElimination of privileges of a holding regime of the Danish companies

Elimination of privileges of a holding regime of the Danish companies

If the Danish company receives from the subsidiary, directly or indirectly, dividends which were not taxed, in this case, withholding taxes are levied on the dividends received if the Danish company is not the beneficial owner of these dividends.

This rule does not apply where the Danish company operates in accordance with the Directive parent-subsidiary companies 90/435.

These changes are affected specifically in the following:
• Withholding tax in amount of 27% deducted from the dividends will be charged to the Danish company possessed by the foreign parent company if these dividends were resulted from the dividends received by the Danish enterprise from foreign subsidiary, and if
• The Danish company is considered as the “pass-though” company, i.e. it is not the ultimate beneficiary of the received dividends, and if
• The parent company for Danish company is the one out of the European Union.
• It is applied to dividends which are paid to the parent company that does not have Double Tax Treaty countries.
• The tax on dividends decreases in accordance with the agreement on avoidance of the double taxation concluded with the country of the parent company.

These changes apply to dividends paid from 01.01.2013 and on.