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Denmark to Remove Possibility of Retroactive Effective Dates for Mergers

|Proposed Changes|Denmark
Denmark

The Danish government has submitted draft legislation to parliament that would amend the Merger Tax Act to remove the possibility of applying an effective date of a cross-border merger for tax purposes that is before the actual merger date. The need for the amendment is in relation to an unintended consequence under current law that income earned in Denmark can avoid Danish taxation in cases of a tax-free cross-border merger (and certain other cross-border corporate restructuring) involving …

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