[Code of Federal Regulations]
[Title 26, Volume 18, Parts 500 to 599]
[Revised as of April 1, 2000]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR521.7]

[Page 140-141]
 
                       TITLE 26--INTERNAL REVENUE
 
     CHAPTER 1--INTERNAL REVENUE SERVICE DEPARTMENT OF THE TREASURY 
                               (Continued)
 
PART 521--DENMARK--Table of Contents
 
                       Subpart--Withholding of Tax
 
Sec. 521.7  Addressee not actual owner.

    (a) If the recipient in Denmark of any dividend from sources within 
the United States is a nominee or representative through whom the 
dividend flows to a person other than a person described in 
Sec. 521.2(a) as being entitled to the reduced rate of 15 percent 
provided in Article VI of the convention, such recipient in Denmark will 
withhold an additional amount of United States tax equivalent to the 
difference between the United States tax which would have been withheld 
had the convention not been in effect (30 percent as at the date of 
approval of this subpart) and the 15 percent withheld at the source with 
respect to such dividend pursuant to Sec. 521.2.
    (b) In any case in which a fiduciary or a partnership with an 
address in Denmark receives, otherwise than as a nominee or 
representative, a dividend from a United States corporation, if a 
beneficiary of such fiduciary or a partner in such partnership is not 
entitled to the reduced rate of tax provided in Article VI of the 
convention, the fiduciary or partnership will withhold an additional 
amount of United States tax with respect to the portion of such dividend 
included in such beneficiary's or partner's net distributive share of 
the income of such fiduciary or partnership, as the case may be. The 
rate of the additional tax is calculated in the same manner as under 
paragraph (a) of this section.
    (c) The amounts so withheld by the withholding agent in Denmark 
will, on

[[Page 141]]

or before the 15th day after the close of the calendar year quarter in 
which such withholding has taken place, be deposited with the Danish 
National Bank (Danmarks Nationalbank) without converting such amounts 
into dollars. Each withholding agent making such deposit will accompany 
such deposit with the appropriate Danish form executed as required by 
the Danish National Bank. The Danish National Bank has arranged to 
remit, on or before the end of the calendar month in which such deposit 
is so made, by draft in United States dollars, the amounts so deposited 
to the District Director of Internal Revenue, Baltimore, Maryland, 
U.S.A., forwarding with such draft the appropriate Danish form filed by 
the withholding agents.