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Denmark ratifies new US treaty protocol

The revised protocol to the Denmark-US tax treaty, signed on 2 May 2006, was ratified by the Danish parliament on 15 December. The protocol, which will update the 1999 protocol, provides for a reduction to zero of the Danish and US withholding tax rates on dividends for certain qualifying shareholders. It also includes a new limitation of benefits clause. The protocol will enter into force after ratification by both countries.

The Danish Ministry of Taxation also announced that Denmark's controlled foreign corporation tax rules are to be reviewed in respect of the European Court of Justice's judgment in Cadbury Schweppes.

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