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Denmark: Summary of recent tax legislative developments

Denmark: Summary of recent tax legislative developments

Tax developments in Denmark in early October 2019 include the following items.


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Updated guidance on reporting obligations for shares, dividends, and bonds: The Danish tax authorities in early October 2019 published guidance on the reporting obligations of taxpayers in respect of the purchase, holding, and sale of shares; the acquisition, disposal and redemption of bonds; and the reporting of dividends. The updated guidance applies for the 2019 tax year.

Legislative amendments presented to Parliament: The Danish government in early October 2019 proposed legislative changes, the majority of which, if approved, would be effective beginning 1 January 2020. Key measures include:

  • Amendments to Danish controlled foreign corporation (CFC) rules
  • Amendments to the definition of a permanent establishment to align with the EU ATAD and the 2017 OECD Model Tax Convention

Legislative proposals to implement Council Directive EU 2018/822 of May 2018 on mandatory disclosure rules and amendments to Danish transfer pricing, interest deductibility, and dividend withholding tax rules were also presented. Draft legislation for the measures mentioned above is expected to be published on a piecemeal basis between now and February 2020.

Consultation launched on amendments to investment income and capital gains tax: The Danish Government in early October 2019 launched a consultation on draft measures to amend as of 1 January 2020 the tax treatment of tax-exempt business transformations, certain acquisition costs (valuation), and certain debt-reduction transactions between related companies, and to introduce the taxation of stock dividends as personal income for mutual funds partners.

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