The Danish Supreme Court has issued a release on a judgment delivered on 4 May 2023 concerning the taxation of interest payments on intra-group loans according to Danish tax legislation, the EU Interest and Royalties Directive, and relevant tax treaties. The judgment covers two similar cases where taxpayers claimed an exemption from withholding tax (or reduced tax) on interest payments.
The first case involved Nycomed A/S (now Takeda A/S), which was involved in a restructuring that include…