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Danish Tax Board Holds External Debt Covered by Parent's Collateral is Subject to Thin Capitalization Rules

|Approved Changes|Denmark
Denmark

Denmark has published a 28 April 2020 Tax Board decision concerning a question of whether or not the thin capitalization (4:1) rule under Denmark's interest deduction restrictions applies in a case where a subsidiary (the taxpayer) had taken out an external loan and collateral had been provided by the parent company in the form of self-payment guarantee and shares of the company. The subsidiar…

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