The Danish Supreme Court’s Decisions on Withholding Tax on Dividends and Interest

In this article, the author discusses the final decisions from January and May 2023 of the Danish Supreme Court in the Danish beneficial ownership cases. The Supreme Court ruled on the consequences of the ECJ preliminary rulings but also took a position on questions of principle on the interpretation of tax treaties and domestic Danish tax law. The Supreme Court ruled that the Danish companies were liable for Danish withholding tax.