Denmark: Foreign state entities and institutions no longer eligible for tax exemption


Clearstream Banking1 informs customers that the Danish Parliament have approved a new bill, that will revoke the current possibility for beneficial owners that are foreign states and institutions to benefit from a withholding tax exemption on Danish dividends distributions via the domestic law. Effective

1 March 2023

the Danish Tax Authorities will as a consequence, revoke all tax exemption cards (“Frikort”- Form 06.009) that are currently issued to such beneficial owners, as of this date.

Qualifying foreign states and institutions may, however, request a reduced rate via a Double Taxation Treaty (DTT), if applicable.

Impact on customers

Clearstream Banking will as above date no longer offer full tax exemption via domestic law to beneficial owners that are foreign states and institutions.

Beneficial owners that are residents of a Double Taxation Treaty (DTT) country may however reclaim withholding tax on dividends using the standard refund procedure.

Further information

For further information, please contact the Clearstream Banking Tax Help Desk or Clearstream Banking Client Services or your Relationship Officer.
1. Clearstream Banking refers collectively to Clearstream Banking AG, registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500, and Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-9248.