Denmark – Poland Tax Treaty
The Denmark-Poland tax treaty caps withholding on dividends at 15% for portfolio investors and 5% for qualifying direct investment, with interest payments fully exempt at 0%. Royalty rates vary by category, from 0% on copyright to 5% on film and television. Private pensions are taxable only in the country of residence, with no withholding at source. This is one of 36 active treaties in Denmark's network and one of 40 in Poland's. The general dividend rate of 15% compares to a median of 15% across Denmark's network and 15% across Poland's.
Verified data
Skattestyrelsen (skat.dk) - Tax Treaties overview and individual treaty texts (Treaty list verified April 2026. Rates from individual treaty texts (Articles 10-12). Note: Denmark has 0% domestic WHT on interest but 22% on royalties paid to non-treaty residents.)
Withholding Rate Summary
Source: Denmark Treaty Reference| Income Type | Treaty Rate | Statutory Rate (Denmark) |
|---|---|---|
| Dividends (general) Portfolio investors | 15%saves 12% | 27% |
| Dividends (qualified) Beneficial owner is a company holding >= 10% of voting stock | 5%saves 22% | 27% |
| Interest Bank interest, bonds, loans | 0% | 0% |
| Royalties (avg) Patents, copyright, know-how, film/TV | 1.3% | — |
| Pensions Private pension distributions | 0% | — |
| Social Security Government social security benefits | 0% | — |
“Treaty Rate” is the maximum withholding permitted under this treaty. The actual effective rate may be lower if domestic law provides a more favorable rate independently. “Statutory Rate (Denmark)” shows the rate that applies when no treaty benefit is claimed. Qualified dividend rate requires: Beneficial owner is a company holding >= 10% of voting stock.
Dividends
The general dividend rate of 15% applies to portfolio investors. A reduced rate of 5% is available when beneficial owner is a company holding >= 10% of voting stock. Without the treaty, the statutory withholding rate on dividends is 27%.
Source: Denmark Treaty Reference
Interest
Interest payments (bank interest, bonds, loans) are subject to 0% withholding under this treaty, compared to the 0% statutory rate. Interest is fully exempt from source-country withholding under this treaty.
Source: Denmark Treaty Reference
Royalties
Royalty withholding rates vary by the type of intellectual property. This treaty distinguishes 4 categories, with rates ranging from 0% to 5%.
Source: Denmark Treaty Reference
Pensions & Social Security
Private pension distributions are taxable only in the country of residence, with no withholding at source. Government social security benefits are exempt from source-country withholding.
Source: Denmark Treaty Reference
Comparative Context
🇩🇰Denmark's Network
Among Denmark's 36 active treaty partners, the 15% general dividend rate ranks 28th (median: 15%).
| Partner | Rate |
|---|---|
| New Zealand | 15% |
| Philippines | 15% |
| Pakistan | 15% |
| Poland (this treaty) | 15% |
| Romania | 15% |
| Sweden | 15% |
| Singapore | 15% |
🇵🇱Poland's Network
Among Poland's 40 active treaty partners, the 15% general dividend rate ranks 22th (median: 15%).
| Partner | Rate |
|---|---|
| Chile | 15% |
| Colombia | 15% |
| Germany | 15% |
| Denmark (this treaty) | 15% |
| Spain | 15% |
| Finland | 15% |
| France | 15% |