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Denmark Tax Agency Explains Tax Treatment of Transfers to Nonprofit Foundation, Dividend Restriction Lifting

Aug. 29, 2022, 5:00 AM

The Danish Customs and Tax Administration Aug. 19 posted online Decision No. SKM2022.396.SR, explaining the tax treatment of transfers to a nonprofit foundation. A taxpayer and his children were sole shareholders in holding companies that owned capital shares in a corporate group. The taxpayer sought clarification on the tax consequences of plans to restructure the group, including the transfer of newly established holding company shares to a nonprofit foundation, cash transfers, and the removal of dividend restrictions on certain shares. The tax agency clarified that because the fund is a nonprofit foundation, not a family fund that grants preferential rights ...