Danish Tax Agency Clarifies VAT Treatment of Business Activity Transfers in Corporate Restructurings

The Danish Customs and Tax Administration Feb. 28 posted online Tax Council Binding Answer No. SKM2025.111.SR, clarifying the VAT treatment of business activity transfers in corporate restructurings. The taxpayer, a service company in a group, underwent a restructuring in which it transferred an activity to a new subsidiary in the group through a contribution in kind, then the activity was transferred to another group company in a vertical merger. The subsidiary was dissolved after 20 days and wasn’t VAT registered. The taxpayer sought clarification as to the VAT treatment of the contribution in kind. The Tax Council confirmed that: 1) ...