Denmark Tax Agency Clarifies Taxation of Dividends, Intra-Group Loan Interest in Restructurings

The Danish Tax Council June 2 posted online Tax Council Binding Answer No. SKM2026.259.SR, clarifying taxation of dividends and intra-group loan interest in restructurings. The taxpayer, a foreign alternative investment fund, was in a group that restructured, which involved share transfers financed with promissory notes. The taxpayer inquired as to taxation of dividends and intra-group loan interest. On review, the Tax Council found that: 1) there was no limited tax liability under the Corporation Tax Act on dividends flowing up the structure to the taxpayer, because the taxpayer was considered the rightful owner of the dividends; 2) interest on intra-group ...