Denmark: Foreign corporations eligible for a reduced withholding tax rate


Clearstream Banking1 informs customers that effective

1 July 2016

a law amendment L 123 was passed on 2 June 2016 by the Danish Parliament, implying that foreign corporations can now benefit from the same reduced withholding tax rate of 22% on dividends from Danish equities as Danish corporations, instead of the current rate of 27%.

The amended law brings Danish legislation into line with EU legislation, which requires that EU/EEA investors receiving dividends are treated equally in taxation.

The amendment will as well be applicable to corporations that are resident outside of the EU/EEA.

Impact on customers

The general withholding tax rate applied to non-residents will remain at the current rate of 27% on dividend distributions from Danish equities. However, in accordance with the amended legislation, EU/EEA foreign corporations, that are not covered by any Double Taxation Treaty are now eligible to obtain a reduced rate via a standard reclaim retroactively as follows:

Tax year

Tax rate applicable:

2007 to 2013








Foreign corporations that are not EU/EEA resident are only eligible to obtain a reclaim for payments as of 1 July 2016 and not for past payments.

Further information

For further information, please contact the Clearstream Banking Tax Help Desk, Clearstream Banking Client Services or your Relationship Officer.
1. Clearstream Banking refers collectively to Clearstream Banking AG, registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500, and Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-9248.