Denmark Tax Agency Clarifies Taxation of Distributed Dividends

December 31, 2025, 5:00 AM UTC

The Danish Customs and Tax Administration Dec. 5 posted Tax Council Binding Answer No. SKM2025.688.SR, clarifying the taxation of distributed dividends. The taxpayer, a subsidiary wholly owned by a nonresident parent company, sought clarification on whether the distribution of dividends to the parent company was exempt from Danish tax liability based on the mutual agreement that determined that the taxpayer was tax resident in another country, and whether the intended distribution of the specified receivable wasn’t subject to Danish tax liability. Upon review, the Tax Council found that: 1) it couldn’t confirm that the distribution of dividends from the taxpayer ...

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