Denmark Tax Agency Clarifies Dividend Withholding Tax Obligations Under EU Parent-Subsidiary Directive

The Danish Customs and Tax Administration Oct. 29 posted online National Tax Court Decision No. SKM2025.606.LSR, clarifying dividend withholding tax obligations under the EU parent-subsidiary directive. The taxpayer, a Danish company, was owned by a Cypriot company under the ownership of a Guernsey company, which was ultimately controlled by a U.K. resident. The taxpayer paid dividends to a partly owned French company and redistributed them from the Cypriot company to the Guernsey company without withholding tax under the EU directive benefit. The Tax Agency denied the benefits, contending that the Cypriot company was established without commercial reasons. Upon review, the ...