Denmark Tax Agency Clarifies Tax Consequences for Loans Between Companies Owned by Same Shareholder

The Danish Customs and Tax Administration March 28 posted online Tax Council Decision No. SKM2025.176.SR, clarifying the tax consequences for loans between companies owned by the same shareholder. The taxpayer, an individual, owned all the capital in both a Danish holding company and a nonresident company. Because the Danish company had liquid capital available, the taxpayer wanted the Danish company to make loans to the nonresident company for funds it needed to borrow for business investments. The taxpayer sought clarification on whether loans from the Danish company to the nonresident company could be made without tax consequences for the taxpayer. ...