The U.S. IRS has published a competent authority arrangement (CAA) signed with Denmark in March 2025 concerning the types of pension entities that are considered qualifying pension funds for the purpose of the treaty benefits (exemption) under paragraph 3(c) of Article 10 (Dividends) of the 1999 tax treaty between the two countries. Paragraph 3(c) of Article 10 provides that dividends may not be taxed in the Contracting State of which the company paying the dividends is a resident if the beneficial owner of the dividends is a pension fund, as described in paragraph 2(e) of Article 22 (Limitation of Benefits),...