Exhibit 8.1
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March 19, 2026
DHT Holdings, Inc.
Dear Ladies and Gentlemen:
You have requested our opinion regarding the status of DHT Holdings, Inc. (the “Company”) as a passive foreign investment company (“PFIC”) under the rules of the Internal Revenue Code of 1986, as amended (the “Code”),
and regarding certain statements made under the caption “Tax Considerations—U.S. Federal Income Tax Considerations” in the Registration Statement to be filed with the Securities and Exchange Commission (the “SEC”) on March 19, 2026. Capitalized
terms used but not defined herein shall have the meaning assigned to them in the representation letter issued to us by the Company and dated March 2, 2026 (the “Representation Letter”), and signed by Laila Halvorsen, Chief Financial Officer of the
Company.
In formulating our opinion as to these matters, we have examined such documents as we have deemed appropriate, including (i) the Registration Statement and (ii) the Representation Letter. In addition, we have
examined, and relied as to matters of fact upon, originals or copies, certified or otherwise identified to our satisfaction, of such corporate records, agreements, documents and other instruments and made such other inquiries as we have deemed
necessary or appropriate to enable us to render the opinion set forth below. In such examination, we have assumed the genuineness of all signatures, the legal capacity of natural persons, the authenticity of all documents submitted to us as
originals, the conformity to original documents of all documents submitted to us as duplicates or certified or conformed copies, and the authenticity of the originals of such latter documents. We have not, however, undertaken any independent
investigation of any factual matter set forth in any of the foregoing.
In rendering our opinion, we have assumed, with your permission, that (i) all transactions and arrangements described in the Registration Statement will be effected in the manner described in the Registration
Statement, (ii) all relevant statements set forth in the Registration Statement are true, complete and correct and (iii) the representations made in the Representation Letter are true, complete and correct and will remain true, complete and correct
at all times in the foreseeable future (without regard to any assumptions or qualifications relating to the materiality, knowledge or belief or similar qualifications). If any assumption above is untrue for any reason, our opinion might be
adversely affected and may not be relied upon.
Based upon the foregoing, in our opinion, the Company should not currently be a PFIC and should not be a PFIC in the future, assuming no material change in the nature of the activities and assets of the Company as
described in the Registration Statement and the Representation Letter. In addition, the statements made under the heading “Tax Considerations—U.S. Federal Income Tax Considerations” in the Registration Statement represent our opinion regarding the
material U.S. federal income tax consequences to beneficial owners of common and preferred stock of the Company of the acquisition, ownership and disposition of such common and preferred stock. Our opinion might be adversely affected and may not
be relied upon to the extent that in the future the Company conducts its affairs in a manner inconsistent with its present plans, as reflected in the Registration Statement and the Representation Letter.
Our opinion is based on the current provisions of the Code, the Treasury Regulations promulgated thereunder, published pronouncements of the Internal Revenue Service and case law, any of which may be changed at any
time with retroactive effect. We disclaim any undertaking to advise you of any subsequent changes of the matters stated, represented or assumed herein or any subsequent changes in applicable law, regulations or interpretations thereof. No opinion
is expressed on any matters other than those described.
We hereby consent to the filing of this opinion with the SEC as Exhibit 8.1 to the Registration Statement. We also consent to the reference to our firm under the captions “Tax Considerations—U.S. Federal Income Tax
Considerations” and “Legal Matters” in the Registration Statement. In giving this consent, we do not thereby admit that we are included in the category of persons whose consent is required under Section 7 of the Securities Act or the rules and
regulations of the SEC.
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Very truly yours, |
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/s/ Cravath, Swaine & Moore LLP
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DHT Holdings, Inc.
2 Church Street
Hamilton HM 11
Bermuda