Executive summaryIn June 2018, the Court of Justice of the European Union (CJEU) ruled on a case regarding the Danish withholding tax regime with respect to dividends paid by Danish companies to nonresident investment funds (UCITS) in the United Kingdom (UK) and Luxembourg.1 The case was submitted to the CJEU for a preliminary ruling by the Danish Eastern High Court. The underlying issue in the case was that dividends paid to resident investment funds that had elected to be subject to minimum taxation under section 16 C of the Tax Assessment Act (TAA) were exempt from withholding tax, whereas dividends paid...