Andrzej Krzemienski’s blog has this post on the subject of noexcept:
Even if you explicitly declare your destructor without any exception specification, the compiler will add one for you: the same as it would add if it had to implicitly generate the destructor. If you do not like the exception specification generated by the compiler, you have to explicitly specify it.
So if there’s a reason to throw from a destructor (which is typically frowned upon), you’d better declare noexcept(false).