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Denmark's New Anti-Abuse Rules in Force

18 May 2015

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Approved Changes

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Denmark

New anti-abuse rules entered into force in Denmark on 1 May 2015. The rules are included in legislation adopted on 21 April 2015 that allow the Danish tax authorities to deny EU tax directives benefits and tax treaty benefits in cases of abuse. The rules are based on recent anti-abuse rules added to the EU Parent-Subsidiary Directive, and Action 6 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project, which deals with preventing treaty abuse. The rules apply in regard to the benefits of the EU Parent-Subsidiary Directive, Interest Royalty Directive and the Merger Directive, as well as Denmark's...