Denmark Tax Agency Clarifies Taxation of Dividends, Interest Under Corporation Tax Act, Nordic DTA

The Danish Customs and Tax Administration Sept. 11 posted online Tax Council Binding Answer No. SKM2025.513.SR, clarifying the taxation of dividends and interest under the Corporation Tax Act and 1996 Nordic DTA. The taxpayer, a real estate investment fund tax resident in a Nordic country, sought clarification of tax implications if two Danish subsidiaries it wholly owned distributed dividends to it through two foreign holding companies it wholly owned. Upon review, the Tax Council found that: 1) the holding company covered by the DTA and EU Directive 2011/96/EU, on parents and subsidiaries, would likely be considered the beneficial owner of ...