Traditionally Denmark is not regarded as a financially attractive centre. Corporate tax rates are as high as 28%.however outstanding opportunities are provided by a new Danish holding company regime which came into effect from the 1st of January 1999.Therefore Danish corporations can be used for restructuring the financial transactions of an international nature.
Since 1st of January 1999 dividends payments and capital gains from its foreign subsidiaries can be received by a Danish holding company without incurring any Danish tax liability .However, for availing this facility certain requirements have to be met.
Denmark has a full membership of the European Union. Benefit must be reaped by the Danish holding company from the European Union Directive 90/435. Through this directive it is endeavored to make the member states stop withholding tax on the dividend which is paid between two countries. Therefore a Danish holding company, on the condition that it meets certain specified criteria, would be able to receive dividends from other member states without the withholding of tax on those dividends. Denmark has also signed tax treaties with over 60 countries. This includes trading majors both outside and inside the European Unions which try to eliminate or at least reduce the withholding of tax which would be, otherwise, incurred on the dividends paid. A Danish company which is correctly structured would be able to reap benefits from the treaties which Denmark has signed. A detailed structure of such treaties and the name of the countries are easily available.
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