Denmark–MNE Tax

Denmark

Taxpayers given six months to challenge Denmark transfer pricing assessments based on insufficient documentation

July 23, 2019

The Danish tax administration on July 12 published a decree specifying new transfer pricing documentation rules and allowing some transfer pricing cases to be reopened where discretionary assessments were made, write Johnny Bøgebjerg and Henrik Lund of KPMG Acor Tax, Denmark. . . .

Asia-Pacific

Sri Lanka, Denmark to revise tax treaty: Economynext→

June 6, 2019

Belgium

Denmark must adopt EU controlled foreign company tax rules, Commission says

July 30, 2019

The EU Commission on July 25 decided to send a reasoned opinion to Denmark for its failure . . .

Denmark

Denmark finance minister endorses global minimum tax for multinational groups, common tax base

March 4, 2019

Denmark’s ruling party, Venstre, supports the global adoption of a minimum tax on multinational group profits, Denmark’s finance minister said on March 3. The minister also . . .

Denmark

Denmark bill implementing EU ATAD proposes new rules for CFCs, interest, exit tax, GAAR, hybrids: EY→

October 4, 2018

Danish tax law denying cross-border loss relief is invalid, EU court rules

June 18, 2018

Davide Anghileri of the University of Lausanne discusses a June 12 decision of the EU Court of Justice which concludes that a Danish law that precludes the deductibility of final losses incurred by a foreign permanent establishment violates EU law . . .

Denmark

Microsoft wins Danish transfer pricing case involving remuneration for marketing activities: Donal O’Donovan / Independent.ie→

March 29, 2018

Denmark

Denmark court says no deemed compensation in transfer pricing case involving restructuring

October 24, 2018

Michael Vorndran, Nord Advisory AS, discusses a new transfer pricing decision of Denmark’s National Tax Tribunal where the court rejects the tax authority’s assertion of additional taxes from the liquidation of a Danish subsidiary in a group-wide restructuring . . .

EU court to consider beneficial ownership definition for interest and royalty directive

March 7, 2017

The European Court of Justice (ECJ) on March 6 published a reference for a preliminary ruling in a Danish case (C-682/16) requesting guidance on the interpretation of the term “beneficial owner” in the context of the EU interest and royalty directive, writes Davide Anghileri of the University of Lausanne . . .

Denmark

Danish government proposes capital gains tax cut: Julie Astrid Thomsen / Reuters→

August 30, 2017

Final losses of foreign subsidiary’s PE must be deductible, EU court rules

July 10, 2018

Davide Anghileri of the University of Lausanne discusses a July 4 decision of the European Court of Justice which invalidated a Danish law that denied loss deductions incurred by a Danish PE of a Danish company’s non-resident subsidiary. . .

Asia-Pacific

Japan, Denmark sign new tax treaty

October 12, 2017

The governments of Japan and Denmark on October 11 signed new tax treaty, Japan’s Ministry of Finance has announced. The new treaty, signed in Tokyo, would amend the countries’ 1968 tax treaty, revising the taxation . . .

Africa

US has agreed to country-by-country tax info exchange with 11 countries, OECD says

June 22, 2017

The United States has so far put in place 11 bilateral competent authority arrangements for the automatic exchange of country-by-country reports, the OECD reported a June 22 release. The US now has . . .

Sweden, Denmark, Finland state opposition to EU digital services tax on revenue: Reuters→

June 7, 2018

Asia-Pacific

Singapore, Denmark sign tax information exchange agreement

March 15, 2017

Singapore and Denmark signed an agreement for the automatic exchange of financial account information on . . .

Denmark’s dividend withholding regime for foreign funds contrary to EU law, Advocate General says

December 20, 2017

European Court of Justice Advocate General Paolo Mengozzi on December 20 issued his opinion that Denmark’s withholding tax regime for foreign investment funds is contrary . . .

Ireland, Sweden, Denmark, Netherlands, UK, Malta, Luxembourg contesting CCCTB, Irish MEP says: Sean Duffy / Independent.ie→

January 9, 2017

See: Independent.ie.

CJEU rules Denmark must grant exemption for interest not deductible under German thin capitalization rules: Meijburg & Co→

December 22, 2016

See: Meijburg & Co. For the decision, see: Masco Denmark.

Americas

US court dismisses FATCA challenges brought by Rand Paul, others: Sally P. Schreiber / CGMA Magazine→

April 27, 2016

See: CGMA Magazine.

Asia-Pacific

Novo Nordisk becomes first pharmaceutical to sign bilateral APA with China

February 28, 2019

Novo Nordisk has concluded a bilateral advance pricing agreement (APA) with the Chinese tax . . .

Denmark

Denmark issues final rules implementing BEPS transfer pricing documentation: Deloitte→

June 2, 2016

See: Deloitte.

Denmark

Netherlands, Denmark sign tax treaty protocol

May 10, 2018

The Dutch government has announced the signing of a protocol to . . .

Asia-Pacific

Feedback sought in review of 8 countries’ tax dispute resolution processes

June 10, 2017

The OECD on June 9 asked multinational firms to provide feedback regarding their experiences with the tax dispute resolution processes in the Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore and Spain. The eight countries’ mutual . . .

Asia-Pacific

Japan to sign tax treaties with Denmark and Estonia

May 15, 2017

Japan’s Ministry of Finance today announced that it has reached agreements in principle for tax treaties . . .

Asia-Pacific

OECD publishes reports covering cross-border tax dispute resolution in Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, Spain

March 13, 2018

The OECD today published reports approved by the “Inclusive Framework on BEPS” which assess tax dispute resolution practices in the Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, and Spain. As members . . .

Denmark

EU court to hear challenge to Denmark’s withholding tax on dividends paid to foreign investment funds

November 14, 2016

The European Court of Justice has published a reference for a Danish case (C-480/16) in the . . .

Australia

31 nations sign agreement on exchange of country-by-country transfer pricing reports

January 27, 2016

In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting . . .

Fidelity wins EU court challenge to Danish withholding tax on dividends paid to foreign funds

June 25, 2018

Davide Anghileri of the University of Lausanne discusses a June 21 decision of the Court of Justice of the European Union in a case brought by Fidelity mutual funds concluding that Denmark’s withholding tax on dividends paid to foreign funds is invalid . . .

Africa

Australia releases draft law adopting BEPS MLI, seeks to amend 30 bilateral tax treaties

February 8, 2018

The Australian government on February 8 released for public comment a draft law that would give the force of law to a multilateral tax treaty designed to amend about 30 of Australia’s tax treaties with other . . .

Denmark

Denmark tax ruling finds that foreign company had PE from service contract with Danish company: EY→

August 29, 2017

Denmark

Danish Supreme Court upholds decision in Microsoft transfer pricing case

March 5, 2019

Michael Vorndran, a principal with Nord Advisory AS, Oslo, discusses the Danish Supreme Court’s decision in Microsoft Denmark ApS. . .

Asia-Pacific

Denmark-Japan double tax treaty enters into force

January 3, 2019

Michael Vorndran, a principal with Nord Advisory AS, Oslo, Norway, notes that a new tax treaty between Denmark and Japan has entered into force . . .

Americas

Brazil clarifies transfer pricing rules, approves protocol to tax treaty with Denmark

February 20, 2019

Francisco Lisboa Moreira, a partner with Bocater, Carmargo, Costa e Silva, Rodrigues, São Paulo, provides an update of recent Brazilian tax developments of interest to MNEs, discussing new Brazilian transfer pricing guidance and the Brazilian Congress’s approval of protocol to the Brazil-Denmark tax treaty . . .

EU Advocate General concludes Danish law denying cross-border loss relief violates EU law

January 22, 2018

Davide Anghileri writes about the opinion of the Advocate General of the Court of Justice of the European Union in the Bevola case, delivered January 17, which concludes that a Danish law that precludes the deductibility of final losses incurred by a company’s foreign permanent establishment violates EU law . .

France, Germany advance compromise for EU-wide digital services tax

November 6, 2018

Germany and France which, along with Italy and Spain, first floated the idea of temporary EU-wide digital services tax, have offered a revised proposal in . . .

Denmark

EU court issues landmark decision on Member State power to deny tax benefits

February 27, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper Nederland N.V. discuss a February 26 European Court of Justice decision which concerns when EU Member States can deny tax benefits granted under the Parent-Subsidiary Directive or the Interest and Royalty Directive when fraud or abuse is involved . . .

Asia-Pacific

Hong Kong signs TIEAs with Denmark, the Faroes, Greenland, Iceland, Norway, and Sweden

August 22, 2014

Hong Kong signed tax information exchange agreements with six jurisdictions on August 22: Denmark, the Faroe Islands, Greenland, Iceland, Norway, and Sweden, according to . . .

Asia-Pacific

UAE, Denmark sign agreement on exchange of information for tax purposes, plan to discuss tax treaty

November 7, 2015

The UAE and Denmark on November 3 signed a tax information exchange agreement (TIEA) in Denmark during a UAE delegation tour of Scandinavian . . .

Denmark

Denmark halts payment of dividend withholding tax refunds pending investigation into fraud by foreign claimants — EY

August 28, 2015

Criminals have allegedly duped Denmark’s tax authority into inappropriately refunding DKK 6.2 billion (approx. €830 million), causing the agency to temporarily suspend payout on pending refund claims, writes EY in an August 27 tax alert. See: EY

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

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