Executive summaryOn 18 May 2020, the Danish Government published an agreement (the Agreement) between the Danish Ministry of Taxation and Finance Denmark (the Danish business association for the banking industry) on a new withholding tax on dividends regime. Under the proposed regime, dividend withholding tax (WHT) would be based on relief at source principles with custodian banks playing a central role and taking on liability for faulty withholding.Detailed discussionIn August 2015, the Danish Tax Authorities suspended the processing of all dividend WHT refund claims with immediate effect due to alleged dividend reclaim tax fraud of approximately DKK12.7 billion.The Danish Ministry of Taxation,...