Denmark Tax Agency Clarifies Taxation of Indirect Loan Between Two Companies Under Common Control

The Danish Customs and Tax Administration Feb. 27 posted City Court Decision No. SKM2026.106.BR, clarifying the taxation of an indirect loan between two companies under common control. The taxpayer, an individual, controlled both the lending and borrowing companies and arranged an intercompany loan, arguing that the transaction served a business purpose, claiming that specific transfers reflected errors, and denying that the funds passed through his personal finances. The National Tax Court held that the loan flowed from the taxpayer’s controlling influence and treated the amount as taxable. On appeal, the City Court found that the taxpayer: 1) exercised controlling influence, ...