Denmark Tax Agency Clarifies Withholding, Dividend Tax Refund Requests for U.S.-Domiciled Investment Funds

The Danish Customs and Tax Administration Sept. 26 posted online National Tax Court Decision No. SKM2025.545.LSR, clarifying withholding and dividend tax refund requests for U.S.-domiciled investment funds. The taxpayer, an investment fund, was domiciled in the U.S. The taxpayer invested in Danish listed shares and had withholding and dividend tax withheld at a 27 percent rate in income years 2015 through 2020. The taxpayer requested that the Tax Agency refund 15 percent of the gross dividends received. The Tax Agency rejected the taxpayer’s request. In upholding the Tax Agency’s decision, the National Tax Court found that: 1) the taxpayer wasn’t ...