Denmark Tax Agency Clarifies Calculation of Alternative Percentage Rate Under Corporation Tax Act

The Danish Customs and Tax Administration April 22 posted online Tax Council Binding Answer No. SKM2026.197.SR, clarifying the calculation of the alternative percentage rate under the Corporation Tax Act. The taxpayer, a group company, sought clarification on whether the alternative percentage rate should be calculated according to tax or accounting principles if the group had hybrid bonds classified as equity for accounting purposes but considered debt for tax purposes. Upon review, the Tax Council found that: 1) only the amounts in the consolidated financial statements should be used as the basis for calculating the alternative percentage rate, not the tax-defined ...