New article on Interest Limitation Rules

Michael Tell has written an article about Danish interest limitation rules. The article analyses the complex Danish interest limitation rules in the Corporate Tax Act (SEL §§ 11, 11B and 11C), hereunder the compatibility with EU law.

Furthermore, the paper discusses alternative methods to evaluate the Danish interest limitation rules.

Read his article here.

New article on Exit Taxation

Michael Tell has recently published a new article on “Exit Taxation After Commission v Denmark C-261/11”.

The article discusses a legislative proposal from the Minister of Tax that has to ensure the Danish rules being in compliance with EU law. The author is though skeptical about the proposal which includes a deferral of payment limited to a maximum of 7 years.

Read his article here.

Two new articles on share exchange agreements

Karsten Gianelli has written two articles concerning taxation of share exchange agreements.

The first article is about the fundamentals of share exchange agreements in Danish tax law, and the needs for a legislative amendment.

Read the first article here.


The second article discusses share exchange agreements in the light of the Danish Tax Board’s policy change in SKM2013.763.SR.

Read the second article here.