Denmark Tax News
ECJ: Decision by reasoned order in UK CFC and foreign dividend test case
ECJ: Advocate General finds Belgian rules on inclusion of dividends in taxable base followed by 95% deduction insofar as parent company makes profits incompatible with Parent-Subsidiary Directive – details
European Commission closes infringement procedure against Luxembourg concerning taxation of dividends
ECJ: Non-deductibility of foreign PE losses in Germany compatible with EC freedom of establishment
ECJ: Netherlands refund regime for investment funds incompatible with EC free movement of capital
Draft of 2008 Model Tax Convention – Proposed changes to Commentary to Art. 12 (definition of royalties)
Reduced withholding tax rates
European Commission takes steps against Bulgaria, Portugal, Romania and Spain concerning taxation of dividends
ECJ: 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive
European Commission refers Netherlands to ECJ for not exempting dividends paid to companies established in certain EFTA countries from withholding tax
Proposed anti-abuse rule on taxation of convertible bonds
Bill to terminate treaty with Spain adopted by Danish parliament
Bill to terminate treaty with France adopted by Danish parliament
European Commission takes steps against Belgium for failure to adopt implementing measures of Merger Directive
ECJ: Advocate General finds German rules on taxation of cross-border dividends under old imputation system compatible with EC law
ECJ: Advocate General finds 5% add-back of tax credits for withholding tax abroad compatible with Parent-Subsidiary Directive – details
Treaty between Denmark and Austria ratified
European Commission takes steps against Germany, Estonia and Czech Republic regarding taxation of outbound dividends
European Commission issues communication regarding accession of Bulgaria and Romania to Arbitration Convention
ECJ: Swedish legislation limiting exemption of third-country dividends justifiable restriction on EC free movement of capital – details
OECD released discussion draft on transactional profit methods
ECJ: Advocate General finds the 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive
Protocol to treaty between United States and Denmark enters into force
Treaty between Denmark and Austria – bill reintroduced
Government reintroduces tax bills
ECJ:Swedish legislation limiting exemption of third-country dividends justifiable restriction on EC free movement of capital
Treaty between Denmark and France – bill reintroduced
Protocol to treaty between United States and Denmark ratified by US Senate
Communication published on application of anti-abuse measures in area of direct taxation – within the EU and in relation to third countries
ECJ: German transitional rules for taxation of capital gains incompatible with EC free movement of capital
Unify Your Processes
Simplify Compliance
Empower Your Team