Denmark: Supreme Court confirms 5-year reclaim period for WHT reclaims
LuxCSD informs clients that on 11 June 2026, the Danish Supreme Court confirmed that the statutory limitation period for Danish withholding tax (WHT) reclaims for non-resident investors is five years from the dividend payment date. The Court ruled that the Danish Tax Authority’s 2016 administrative change to a three-year period was not legally valid.
Impact on clients
The Danish Tax Authority is yet to issue operational guidance for managing past and future standard refund for the new deadline. LuxCSD will provide a further update as soon as these details are clarified.
Further information
Clients may contact the Tax Help Desk, LuxCSD Client Services or their Relationship Officer.
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1. LuxCSD refers to LuxCSD S.A., registered office at 42, Avenue J.F. Kennedy, L-1855 Luxembourg, registered with the Luxembourg Trade and Companies Register under number B-154.449.