Denmark Tax Agency Clarifies Withholding of Dividend Tax for Foreign Investment Funds

The Danish Customs and Tax Administration Aug. 29 posted National Tax Court Decision No. SKM2025.471.LSR, clarifying the withholding of dividend tax for foreign investment funds. The taxpayer, a Finnish investment fund, sought a refund in 2014 of dividend tax withheld on 2009 and 2012 dividends paid to its fund manager on Danish listed shares. The Tax Agency denied refund as time-barred. On appeal, the National Tax Court found that: 1) the earliest the taxpayer could seek a refund was when the tax was withheld from the payments, and the payments were made more than five years before the refund claim; ...