Recent Danish tax decisions challenge established assumptions about ADRs.

Three rulings from the Danish National Tax Tribunal revisit a fundamental question: can holders of American Depositary Receipts (ADRs) be regarded as shareholders of the underlying company for tax purposes?

The decisions appear to adopt a more restrictive approach than previous Danish tax practice, with potential implications for withholding tax refunds and cross-border investors.

In this article Katja Dyppel Weber explores the tax qualification of ADRs and the consequences of these developments.

Read the full article here.