On 25 January 2015, Danish tax authorities issued draft anti-abuse legislation including  rules that would deny tax treaty benefits and EU tax directives 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 would apply in regard to the EU Parent-Subsidiary Directive, Interest Royalty Directive and the Merger Directive, and would apply for both current and future tax treaties. The EU directives anti-abuse rule essentially states that Denmark will not grant...