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Denmark proposes nonresident taxation on interest related to Danish real estate and expanded withholding tax obligation

13 March 2025

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Tax Alerts, Legislation & Policy, Na...

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Denmark

From 1 July 2025, Denmark proposes to tax interest incurred on loans related to Danish real estate that nonresident companies pay to affiliated nonresident companies; a tax is also proposed for capital gains on loans financing real estate in Denmark.Further, the scope of the withholding tax obligation would be expanded in relation to interest and capital gains stemming from loans and royalties. Executive summaryOn 12 March 2025, the Danish minister of taxation published a draft bill for public hearing that proposes a tax on interest that nonresident companies pay to affiliated nonresident companies if the underlying controlled debt is allocable to...