On 21 December 2016, the European Court of Justice issued its decision in the Case C 593/14 (Masco Denmark ApS/Damixa ApS). The case relates to the Danish rules concerning the treatment of interest income received by a resident company but the deduction of which was disallowed at the level of the payer pursuant to thin-capitalization rules.
The Danish thin-capitalization rules applied initially only to non-resident lenders. In 2004, the rules were extended to cover pure domestic lending rel…