Denmark Tax Agency Issues Control Signal on Tax Treatment of Withdrawals in Tax-Free Corporate Transformations

The Danish Customs and Tax Administration Nov. 11 issued Tax Administration Indicative Guidance No. SKM2025.633.SKTST, clarifying the tax treatment of withdrawals in tax-free corporate transformations. The indicative guidance clarifies that: 1) in tax-free corporate transformations, withdrawals from a company during the period from the beginning of the income year until the company’s incorporation date are considered withdrawals made from the company; 2) the withdrawals are taxed as dividends or wages from the company under the general rules; and 3) withdrawals in the period up to the foundation aren’t covered by the shareholder loan taxation rules under Section 16 E of ...