Denmark Publishes Law Implementing EU Anti-Tax Avoidance Directive Measures

On 28 December 2018, Denmark published Law No 1726, which provides for several amendments to comply with the measures of the EU Anti-Tax Avoidance Directive (ATAD) and the Directive as amended (ATAD2). Key changes included in the law are summarized as follows:

• Changes in the interest deduction limitation rules:
  • The replacement of the 80% of EBIT deduction limit with a 30% of EBITDA limit on excess financing costs, including a safe harbor of DKK 22.3 million;
  • Excess financing costs subject …