Denmark: Holding restriction for residents in tax heaven countries
Further to our Taxflash T21009, concerning the Danish Government’s approved proposal to increase the dividend withholding tax rate to 44% for certain recipients that are registered or tax residents in a tax heaven country, Clearstream Banking1 would like to inform customers that effective
1 July 2021
customers may no longer hold Danish equities or Danish investment funds through Clearstream Banking, in either of the following circumstances:
- The final beneficial owner is registered or tax resident in one of the below stated tax heaven countries; or
- The customer or any other intermediary in the custody chain is registered or tax resident in one of the below stated tax heaven countries.
Note: It is the customer responsibility to put in place all necessary arrangements with respect to investment restrictions and the customer shall be liable for non-compliance.
Please refer to the Holding Restrictions section of the Market Profile – Denmark for further details.
Tax Heaven countries
The countries that are currently considered as tax heaven countries in Denmark are the following:
- American Samoa
- Anguilla
- The US Virgin Islands
- Dominica
- Fiji
- Guam
- Palau
- Panama
- Samoa
- Seychelles
- Vanuatu
Impact on customers
Clearstream Banking will continue to pay Danish dividend distributions with the default rate of 27% withholding tax.
It is however the customer’s responsibility to put in place all necessary arrangements with respect to investment restrictions (please refer to the Holding Restrictions section of the Market Profile - Denmark) and the customer shall be liable for non-compliance.
Further information
For further information, customers may contact the Clearstream Banking Tax Help Desk, Clearstream Banking Client Services or your Relationship Officer.
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1. Clearstream Banking refers collectively to 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, and Clearstream Banking AG (for Clearstream Banking AG customers using Creation Accounts), registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500.