Orbitax subscribers can now easily follow the latest COVID-19-related tax measures being implemented worldwide. New to Orbitax? Create a free account to access your dashboard and latest tax news.
News Share

The Tax Hub

Daily Tax Newsletter


Responsive image

Danish Tax Board Holds External Debt Covered by Parent's Collateral is Subject to Thin Capitalization Rules

Denmark has published a 28 April 2020 Tax Board decision concerning a question of whether or not the thin capitalization (4:1) rule under Denmark's interest deduction restrictions applies in a case where a subsidiary (the taxpayer) had taken out an external loan and collateral had been provided by the parent company in the form of self-payment guarantee and shares of the company. The subsidiary had used the loan to finance the construction of an investment property.

The taxpayer's position was that the collateral provided was in fact worthless, as there were no significant assets in the company other than the shares in and receivables against the subsidiary, and that the financing was on market terms. As such, the external debt should not be regarded as controlled debt. If it is considered controlled, however, the taxpayer's secondary position was that the amount of controlled debt should be calculated considering the value of the collateral provided.

In its decision, the Tax Board did not accept either position. The Tax Board ruled that since collateral had been provided by the parent company, and this was a requirement from the external lender, all external debt should be regarded as controlled debt, as the loan could not have been obtained without the collateral provided. Further, the Tax Board ruled that the calculation of the interest deduction restriction could not be made on the basis of the value of the collateral provided, since the entire secured loan had to be regarded as controlled debt.

Powerful Tax Tools


FX Rates

Global FX Rates including Tax Year Average FX Rates and Spot Rates for all Reporting Currencies.


Corporate Tax Rates

Corporate tax rates, surtaxes, and effective tax rates for the current year, as well as historical rates and approved future rates.


Country Analysis

Detailed tax guidance for companies doing business in over 100 countries, including summaries and snapshots of key tax facts and issues.


Cross Border Tax Calculator

Calculate total tax costs and benefits of a cross border transaction including withholding tax, participation exemption and foreign tax credit rules.


Cross Border Tax Rates

Provides Domestic, treaty and EU cross border tax rates for over 5,000 country combinations for 9 different payment streams.



Complete overview of the OECD BEPS Project, including daily BEPS news, country adoption of BEPS measures, and an overview of the 15 BEPS Actions.


Tax Calendar

Customizable calendar tool that tracks corporate income tax, value added tax and transfer pricing obligations by country or entity.


Tax Forms

English translations of key tax forms for over 80 countries, including tax return forms, treaty benefit forms, withholding tax forms, and more.


Worldwide Tax Treaties

Repository including thousands of tax treaties (in English), OECD, UN and US Models, relevant EU Directives, Technical Explanations, and more.


Worldwide Tax Planner

Calculates the worldwide tax cost of what-if scenarios based on legal entity structure, taxable income, and cross border transactions.


Certified Rates Report

Customizable Certified Rates Report providing updated corporate and withholding tax rates at the end of each month for over 100 countries.


Withholding Tax Minimizer

Enables quick calculation of tax costs and benefits of cross border transactions considering all possible transaction combinations and optimal routes.


VAT Rates

Provides value added tax (VAT) rates, goods and services tax (GST) rates and other indirect tax rates for over 100 countries.


NOL Calculator

Country specific calculator to determine how net operating losses can be utilized in carryback and carryforward years.


Transfer Pricing Calculator

Calculates TP ratios under various TP methods and calculates the difference between target ratios and actual ratios.


Individual Income Tax Rates

Individual tax rates for over 100 countries.

Play of the Day

Translate Documents

English translations of key tax forms for over 80 countries, including tax return forms, treaty benefit forms, withholding tax forms, and more.

We’re here to help

We’re here to answer any questions you have about the Orbitax products and services.

Send us a message

Who’s behind Orbitax?

We’re committed to providing high value, low cost tax research and management solutions.

Learn More