Denmark Tax Agency Explains Application of Hybrid Mismatch Rules for Specific Investment Partnerships

The Danish Customs and Tax Administration April 19 posted online Tax Board Binding Answer No. SKM2021.216.SR, clarifying the application of hybrid mismatch rules to specific Danish investment partnerships. A Danish company was owned by two Danish limited partnerships. Investors of one of the limited partnerships were from countries which consider Danish partnerships to be independent taxable entities. The tax agency was approached to determine the tax status of the Danish company. The agency clarified that: 1) all of the investors in the Danish company were considered to be acting together through the joint management of the two limited partnerships; 2) ...