Denmark Tax Agency Clarifies Corporate Income Taxation of Interest Under DTA With U.K.

The Danish Customs and Tax Administration March 12 posted Tax Council Binding Answer No. SKM2026.136.SR, clarifying corporate income taxation of interest under the 1980 DTA with the U.K. The taxpayer, a Danish holding company, was owned by a Luxembourg investment fund through a U.K. holding company. The investment fund granted the U.K. company two profit participation loans, then the U.K. company granted the taxpayer two loans. The taxpayer inquired whether the U.K. company had limited tax liability in Denmark on interest. The Tax Council found that: 1) waiver of limited tax liability under a DTA requires that the recipient is ...