New article on Exit Taxation

Michael Tell has recently published a new article on “Exit Taxation After Commission v Denmark C-261/11”.

The article discusses a legislative proposal from the Minister of Tax that has to ensure the Danish rules being in compliance with EU law. The author is though skeptical about the proposal which includes a deferral of payment limited to a maximum of 7 years.

Read his article here.

Two new articles on share exchange agreements

Karsten Gianelli has written two articles concerning taxation of share exchange agreements.

The first article is about the fundamentals of share exchange agreements in Danish tax law, and the needs for a legislative amendment.

Read the first article here.

 

The second article discusses share exchange agreements in the light of the Danish Tax Board’s policy change in SKM2013.763.SR.

Read the second article here.

New article on classification of foreign entities

Jakob Bundgaard and Steffen Bonde Jensen have published a new article on the classification of foreign entities. The article tries to summarize the most important criteria that are used when the Danish tax authorities classify foreign entities based on tax decisions during the last five years.

You can read the whole article here.