OrbitaxCJEU Holds Danish Restriction on Offset of Losses of Non-Resident's Danish PE Violates Freedom of Establishment if No Other Possibility to Deduct
|Approved Changes|Denmark-European Union
On 4 July 2018, a judgment of the Court of Justice of the European Union (CJEU) was issued concerning whether Denmark's loss restriction rules in relation to a permanent establishment (PE) in Denmark of a non-resident member of a group violates the EU freedom of establishment principle.
Under Danish law, the scope of national group (joint) taxation includes all companies and PEs belonging to…
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