Denmark has published a 28 April 2020 Tax Board decision concerning a question of whether or not the thin capitalization (4:1) rule under Denmark's interest deduction restrictions applies in a case where a subsidiary (the taxpayer) had taken out an external loan and collateral had been provided by the parent company in the form of self-payment guarantee and shares of the company. The subsidiary had used the loan to finance the construction of an investment property.
The taxpayer's position …