ANNOUNCEMENT 18 Dec 2012In December 2012, the government of Denmark announced altered domestic business conditions for foreign investors.
NUMBER OF INTERVENTIONS
Lexology, "Last chance for tax-exempt distributions?", 18.December 2012:
International Bar Association, Recent Developments in International Taxation-Denmark:
On 18 December 2012, the Danish government passed an act expanding the scope of a foreign withholding tax of 27% (a rate that may be lower depending on Denmark's double tax treaties) on dividends paid out to foreign parent companies.
With the new provisions, the tax will applied on dividends paid by Danish companies to their foreign parent companies, if those dividends were previously received from a non-Danish foreign subsidiary. Also, the tax will be applied on dividends Danish entities receive from foreign subsidiaries, if the Danish parent company is not the beneficial owner of the dividends.
As described by Ottosen and Norremark (cf. Lexology-link in sources), this measure was "aimed at Danish companies being used as 'stepping stones' to avoid or reduce foreign withholding tax".
The new provisions came into force on 1 January 2013.