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Holding Companies in Denmark
The Danish Holding Company first became popular in 1999 when it introduced a broad participation exemption on dividends and capital gains, as well as an exemption from Danish dividend withholding tax under certain conditions.
There is a broad range of uses for Danish holding companies within the arena of international tax planning.
Treaty country equity investment. Treaty countries investing through a Danish Holding Company will ensure that withholding taxes are reduced to 0% regardless of the treaty rate. This is extremely interesting for residents of the US, Canada, Australia and many other jurisdictions planning to invest into Europe and other jurisdictions with which Denmark has a strong treaty.
Offshore equity investment. Tax havens should consider investing onshore via a Danish Holding Company. The profits of the holding activities can be easily repatriated to the offshore parent via liquidation without negative tax consequences. Structures with multiple Danish companies are often implemented in order to facilitate ongoing repatriations.
Repatriation of offshore operating funds. Danish holding companies provide interesting opportunities for repatriating offshore funds into an onshore group. The Danish Holding Company can receive dividends from the offshore entities provided that they are non financial and then inject these funds as capital or loans into its onshore participations.
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