Danish court decides case on cash pooling arrangements

The Administrative Tax Court of Denmark (Landsskatteretten) gave its decision on 21 October 2013 in the case of SKM2014.53.LSR (published on 20 January 2014), which is the first published decision on cash pooling arrangements by the Danish courts. Details of the decision are summarized below.
(a) Facts. The Danish company (DK Co) was a subsidiary of an international group. DK Co entered into a zero-balancing cash pool arrangement with a Swiss sister company (CH Co), which acted as a cash pool ad…