Liquidation proceeds to be paid to individuals may qualify as a dividend payment according to an enacted bill.
Individuals resident abroad and receiving gains from shares in a Danish company are not liable to pay tax to Denmark on such gains, whereas dividend may be subject to Danish withholding tax.
As of today, liquidation proceeds received by individuals and paid in the calendar year of the final dissolution of the relevant company are always taxed as gains on shares (i.e. not taxable to Denmark). However, according to the enacted bill, such liquidation proceeds may qualify as a dividend payment if the individual is domiciled outside the EU/EEA and has a controlling interest in the company liquidated.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.