Denmark Tax Agency Clarifies Joint Taxation in Simultaneous Acquisition, Disposal of Subsidiary by Parent Company

The Danish Customs and Tax Administration Sept. 8 posted online Eastern High Court Decision No. SKM2025.494.OLR, clarifying joint taxation in the simultaneous acquisition and disposal of a subsidiary by a parent company. The taxpayer, a parent company, acquired the entire share capital of subsidiary company (G1) from two other companies (G2 and G3), with a binding agreement that G2 repurchase the shares. The taxpayer argued that there was a basis for joint taxation between G1 and itself for income year 2010, and that the tax assessment for that income year should be remitted for reconsideration by the Danish Tax Agency ...