Denmark: Proposal to increase the dividend withholding tax rate for residents in tax heaven countries approved by Parliament


Further to our Taxflash T21001, concerning the Danish Government’s proposal to increase the dividend withholding tax rate to 44% for certain recipients that are registered or residents in a tax heaven country, Clearstream Banking1 would like to inform customers that the proposal was approved by the Danish Parliament on 20 April 2021 and will become effective on 1 July 2021.

The new increased withholding tax rate on dividends will be applicable, provided the recipient, resident in a tax heaven country is one of the below:

  • Majority shareholders that possesses or have possessed within the last five years:
    • 25 % of the share capital of the company; or
    • More than 50 % of the voting rights in the company.


  • Parent/mother companies that hold at least 10 % of the share capital in the subsidiary companies (“Datterselskabsaktier”);


  • Shares that are held by an allied company –defined in Danish law as: Shares where the owner of the shares and the company the shares are held in are taxed jointly (consolidated companies).

Impact on customers

The operational guidelines on how this withholding tax will be applied are still being clarified by the Danish Tax Authorities.

Further information

We continue to monitor the Danish market for new developments and will provide more information as it becomes available.

For further information, customers may contact the Clearstream Banking Tax Help Desk or Clearstream Banking Client Services or their Relationship Officer.

This Taxflash is intended to provide customers with general information gathered from different sources that are generally believed to be reliable. Clearstream Banking S.A. does not guarantee the accuracy or completeness of the information and does not undertake to keep it up to date. Use of the information made available in this Taxflash is at the customer’s own risk and Clearstream Banking S.A. its subsidiaries and affiliates expressly disclaim any liability for any errors or omissions