Danish Supreme Court Confirms 5-Year Limitation Period for Non-Residents Claiming WHT Refund on Dividends, Royalties

The Danish Supreme Court issued a judgment on 11 June 2026 confirming that claims by non-residents for refunds of over-withheld Danish tax on dividends and royalties are subject to the special 5-year limitation period under section 67A of the Danish Withholding Tax Act, rather than the general 3-year limitation period.

The cases involved three taxpayers that were subject to limited tax liability in Denmark and had requested refunds in 2017 of Danish withholding tax on dividends and royalties…