Takeda Liable for Withholding Tax, Danish Court Rules

A Takeda company was properly liable for 369 million Danish krone ($54.6 million) in uncollected withholding tax on intragroup loan interest, Denmark’s Supreme Court ruled Thursday.

The untaxed interest was paid between 2007 and 2009 by Denmark’s Nycomed A/S to a Swedish parent. Nycomed A/S was later acquired by the Japanese pharmaceutical multinational group Takeda and renamed Takeda A/S. The company has since that time paid the disputed tax.

According to the court, the Swedish parent was a mere flow-through entity and therefore unprotected by Nordic double-tax treaties or the ...