TAXATION
Danish Taxation
The following summary outlines certain Danish tax consequences to U.S. Holders (defined below):
Withholding Tax
Generally, Danish withholding tax is deducted from dividend payments to U.S. Holders at a 27% rate, the rate generally applicable to non-residents in
Denmark without regard to eligibility for a reduced treaty rate. Under the current Convention between the Government of the United States of America
and the Government of the Kingdom of Denmark for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on
Income (the ‘Current Convention’), however, the maximum rate of Danish tax that may be imposed on a dividend paid to a U.S. Holder that does not
have a ‘permanent establishment’ (as defined therein) in Denmark is generally 15% and, for certain pension funds, 0% (each, the ‘Treaty Rate’). U.S.
Holders eligible for the Treaty Rate may apply to the Danish tax authorities to obtain a refund to the extent that the amount withheld reflects a rate in
excess of the Treaty Rate (any such amount, the ‘Excess Withholding Tax’).
Until December 2015, a simplified withholding tax refund procedure was available for U.S. Holders of ADRs. Under the simplified refund procedure,
U.S. Holders of ADRs that provided a properly completed Internal Revenue Service (IRS') Form 6166 to the Depositary would receive a refund from the
Depositary of the Excess Withholding Tax. The simplified procedure was cancelled by the Danish Tax Authorities in December 2015.
Any U.S. Holders of ADRs wishing to apply for a refund of Excess Withholding Tax after December 17, 2015 will have to apply for a refund under the
generally applicable Danish withholding tax refund procedure. In addition to providing a Danish Claim for Refund of Danish Dividend Tax and an IRS
Form 6166, the Danish Tax Authorities will require additional documentation including: proof of dividend received; proof of ownership of the ADR and
eligibility for the dividend received and proof that the dividend received was reduced by an amount corresponding to the Danish withholding tax. These
documentation requirements may be expanded and may be subject to change. Refund claims must be filed within the three-year period following the date
in which the dividend was paid in Denmark.
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