Denmark Tax Agency Clarifies Limited Tax Liability for Dividends, Interest

The Danish Customs and Tax Administration Sept. 15 posted online Tax Council Binding Answer No. SKM2025.524.SR, clarifying the taxation of dividends and interest under the Corporation Tax Act and the Denmark-Luxembourg DTA. The taxpayer, a Luxembourg investment fund structured as a variable capital investment company (SICAV) and qualified as a specialized investment fund (SIF) through two wholly owned Luxembourg holding companies, sought clarification of Danish tax implications if dividends and interest were paid from a Danish subsidiary. Upon review, the Tax Council found that: 1) one of the Luxembourg holding companies, covered by the DTA and EU Directive 2011/96/EU on ...