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Denmark Tax News

ECJ: Advocate General finds French legislation on group consolidation excluding lower-tier subsidiaries indirectly owned through companies in other Member States justifiable restriction on EC freedom of establishment

7 October 2008
OECD released 2008 Model Tax Convention

7 October 2008
Protocol to treaty between Malaysia and Denmark enters into force

30 August 2008
Discussion draft on New Art. 7 of OECD Model – details

30 August 2008
OECD Council approves 2008 Model Tax Convention

11 August 2008
Memorandum of Understanding to treaty between India and Denmark signed – Collection of taxes suspended during MAP

11 August 2008
Preliminary ruling requested from ECJ on interpretation of Merger Directive in connection with scheme to avoid Netherlands property transfer tax

11 August 2008
Anti-abuse rule on taxation of convertible bonds adopted

27 July 2008
Treaty between Denmark and France terminated

27 July 2008
Treaty between Denmark and Spain terminated

27 July 2008
Comments on draft contents of 2008 update to Model Tax Convention published

27 July 2008
Denmark ratifies four agreements with Isle of Man

27 July 2008
ECJ: Netherlands refund regime for investment funds incompatible with EC free movement of capital

21 June 2008
ECJ: Decision by reasoned order in UK CFC and foreign dividend test case

21 June 2008
European Commission takes steps against Bulgaria, Portugal, Romania and Spain concerning taxation of dividends

21 June 2008
Treaty between Austria and Denmark – details

21 June 2008
Reduced withholding tax rates

21 June 2008
European Commission closes infringement procedure against Luxembourg concerning taxation of dividends

21 June 2008
ECJ: Non-deductibility of foreign PE losses in Germany compatible with EC freedom of establishment

21 June 2008
ECJ: Advocate General finds Belgian rules on inclusion of dividends in taxable base followed by 95% deduction insofar as parent company makes profits incompatible with Parent-Subsidiary Directive – details

21 June 2008
Draft of 2008 Model Tax Convention – Proposed changes to Commentary to Art. 12 (definition of royalties)

21 June 2008
ECJ: 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive

14 May 2008
European Commission refers Netherlands to ECJ for not exempting dividends paid to companies established in certain EFTA countries from withholding tax

14 May 2008
Proposed anti-abuse rule on taxation of convertible bonds

14 May 2008
ECJ: Advocate General finds German rules on taxation of cross-border dividends under old imputation system compatible with EC law

16 March 2008
Bill to terminate treaty with France adopted by Danish parliament

16 March 2008
Treaty between Denmark and Austria ratified

16 March 2008
Bill to terminate treaty with Spain adopted by Danish parliament

16 March 2008
European Commission takes steps against Belgium for failure to adopt implementing measures of Merger Directive

16 March 2008
ECJ: Advocate General finds 5% add-back of tax credits for withholding tax abroad compatible with Parent-Subsidiary Directive – details

16 March 2008
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