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ECJ Strikes Down Danish Rules Disallowing Exemption of Interest Non-deductible under German Thin-cap Rules

|Approved Changes|Denmark-Germany-European Union
Denmark-Germany-European Union

On 21 December 2016, the European Court of Justice issued its decision in the Case C 593/14 (Masco Denmark ApS/Damixa ApS). The case relates to the Danish rules concerning the treatment of interest income received by a resident company but the deduction of which was disallowed at the level of the payer pursuant to thin-capitalization rules.

The Danish thin-capitalization rules applied initial…

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