Denmark Tax News
Final Report on Improving the Resolution of Tax Treaty Disputes
ECJ: hearing in case regarding Dutch withholding tax on outbound dividends
Major amendments to Danish tax laws announced
Company tax regimes of Swiss cantons exempting foreign profits incompatible state aid under EU-Switzerland Agreement
EU Commission requests Italy to implement the Interest and Royalties Directive correctly
Report on Attribution of Profits to PEs released
EU Commission progresses infringement actions against Member States for discriminatory taxation of outbound dividends
EU Commission requests Italy not to apply a withholding tax on dividends paid to Netherlands parent companies
ECJ holds French withholding tax on outbound dividends incompatible with freedom of establishment
ECJ: previous UK ACT regime regarding outbound dividends compatible with EC fundamental freedoms (ACT IV GLO) – details
Minister of Taxation's policy statement for 2006/07
Protocol to treaty between Denmark and US
European Commission requested Spain to end infringement to the EC Parent-Subsidiary Directive concerning the use of anti-abuse measures
European Commission refers Italy and Luxembourg to ECJ for not implementing Directive amending EC Parent-Subsidiary Directive
European Commission requests Belgium, Italy, Luxembourg, Netherlands, Portugal and Spain to terminate discriminatory taxation of outbound dividends
European Commission decides that Luxembourg's preferential tax regime for 1929 holding companies constitutes incompatible state aid
US Senate may hold hearings on new Denmark, Finland, and Germany protocols
European Commission requests Belgium to terminate discriminatory taxation of inbound dividends
Proposal to introduce a new tax account adopted
Protocol to treaty between US and Denmark signed
New rules on thin capitalization and withholding tax adopted
The first-time income tax treaty between Denmark and Taiwan, concluded between the Danish Trade Organization's Taipei Office and the Taipei representative office in Denmark on 30 August 2005, entered into force on 23 December 2005. The treaty generally applies from 1 January 2006. Further details will be reported subsequently.
Treaty between Luxembourg and Denmark covers Luxembourg SICAVS and SICAFS and Danish collective investment vehicles
On 27 October 2005 the first-time income tax agreement between Denmark and Taiwan, which was concluded between the Danish Trade Organization's Taipei Office and the Taipei representative office in Denmark on 30 August 2005, was submitted to the Danish parliament for approval. The agreement will not apply to the Faroer Islands and Greenland. Further details will be reported subsequently.
Denmark has recently concluded negotiations for first-time tax treaties with Croatia and Nigeria, and for a first-time agreement with Taiwan. Further details will be reported subsequently.
New group taxation rules and reduction in corporate income tax rate
On 31 May 2005 Denmark approved a law, which provides for a reduction of the corporate income tax rate from 30% to 28% with retroactive effect from 1 January 2005.
Entry into force on 21 December 2004, effective as from 1 January 2005.
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