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Orbitax Tax News & Alerts

Denmark's Tax news & updates from Orbitax and partners

Denmark Tax News

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Discussion draft on application and interpretation of non-discrimination article of OECD Model – details

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Revised bill amending the Corporate Income Tax Act published

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Revised Commentary on Article 7 of OECD Model released

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Memorandum of understanding concluded between Denmark and Switzerland

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ECJ: temporal effects of judgment in Meilicke against Germany should not be limited – details

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Final Report on Improving the Resolution of Tax Treaty Disputes

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Company tax regimes of Swiss cantons exempting foreign profits incompatible state aid under EU-Switzerland Agreement

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Major amendments to Danish tax laws announced

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ECJ: hearing in case regarding Dutch withholding tax on outbound dividends

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Report on Attribution of Profits to PEs released

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EU Commission requests Italy not to apply a withholding tax on dividends paid to Netherlands parent companies

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EU Commission requests Italy to implement the Interest and Royalties Directive correctly

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EU Commission progresses infringement actions against Member States for discriminatory taxation of outbound dividends

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ECJ: previous UK ACT regime regarding outbound dividends compatible with EC fundamental freedoms (ACT IV GLO) – details

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ECJ holds French withholding tax on outbound dividends incompatible with freedom of establishment

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Protocol to treaty between Denmark and US

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Minister of Taxation's policy statement for 2006/07

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US Senate may hold hearings on new Denmark, Finland, and Germany protocols

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European Commission requests Belgium to terminate discriminatory taxation of inbound dividends

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European Commission refers Italy and Luxembourg to ECJ for not implementing Directive amending EC Parent-Subsidiary Directive

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European Commission decides that Luxembourg's preferential tax regime for 1929 holding companies constitutes incompatible state aid

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European Commission requested Spain to end infringement to the EC Parent-Subsidiary Directive concerning the use of anti-abuse measures

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European Commission requests Belgium, Italy, Luxembourg, Netherlands, Portugal and Spain to terminate discriminatory taxation of outbound dividends

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Proposal to introduce a new tax account adopted

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Protocol to treaty between US and Denmark signed

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New rules on thin capitalization and withholding tax adopted

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Treaty between Luxembourg and Denmark covers Luxembourg SICAVS and SICAFS and Danish collective investment vehicles

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The first-time income tax treaty between Denmark and Taiwan, concluded between the Danish Trade Organization's Taipei Office and the Taipei representative office in Denmark on 30 August 2005, entered into force on 23 December 2005. The treaty generally applies from 1 January 2006. Further details will be reported subsequently.

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On 27 October 2005 the first-time income tax agreement between Denmark and Taiwan, which was concluded between the Danish Trade Organization's Taipei Office and the Taipei representative office in Denmark on 30 August 2005, was submitted to the Danish parliament for approval. The agreement will not apply to the Faroer Islands and Greenland. Further details will be reported subsequently.

Orbitax

Denmark has recently concluded negotiations for first-time tax treaties with Croatia and Nigeria, and for a first-time agreement with Taiwan. Further details will be reported subsequently.

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