6 In general, Denmark is now exempt from double taxation by allowing a credit for the Singapore tax paid against Danish tax on the income of its residents. However, in order to continue to encourage Danish investment in Singapore, Denmark is exempt from the dividend that a Singapore-based company distributes to a Denmark-based company that directly or indirectly owns more than 25% of the dividend-paying company`s shares. Dividends paid to a parent company in another EU Member State or in a state with which Denmark has a DTT are exempt from WHT, provided the shares are considered subsidiary shares (and the tax is reduced or abolished in accordance with the DTT directive or EU mother-subsidiary). This means that the parent company can benefit from benefits under the current DTT or the European parent-subsidiary directive. The same applies to dividends paid on shares of the group (which are not subsidiary shares, i.e. holdings of less than 10%), provided the beneficiary company is established in the EU/EEA. 5 In order to reduce double taxation, Singapore will continue to authorise, in the new agreement, the tax paid in Denmark on Singapore`s income as a Singapore tax credit collected in Denmark. With regard to Denmark`s dividends, Danish tax on the portion of dividends on which the dividends were paid is also eligible for tax credits in Singapore where the shareholder is a Singapore-based company that holds at least 10% of the share capital of the dividend payment company. The agreement between the Government of the Russian Federation and the Government of the Republic of Albania to avoid double taxation on the taxation of capital income and interest is generally not subject to the WHT, unless it is paid to a foreign group company established fiscally outside the European Union and outside one of the states with which Denmark has a tax treaty. In this case, interest rates in WhT are 22%.
Some other exemptions apply, mainly with respect to cogeneration tax. If the portfolio shareholder (participation less than 10%) in a country with which Denmark has an agreement on the exchange of tax information (TIEA), the tax rate on the dividend is set at z.B 15% and the difference between the higher WHT rate (27%) drop. and the lower WHT level can be recovered.