Review on recently published book

Peter Koerver Schmidt’s PhD thesis ”Dansk CFC-beskatning – i et internationalt og komparativt perspektiv” has been reviewed by Professor Jane Bolander in Nordic Tax Review.

The Professor finds the book “highly relevant with practical input”.

Read the review here.

New Article on tax losses from hydrocarbon activities

Katja Dyppel Weber has published an article on the Danish tax treatment of tax losses from hydrocarbon activities in the North Sea.

The article explains the tax treatment of losses subject to the transitional rules in the Danish hydrocarbon tax act § 27 C. Further, the interplay between the hydrocarbon tax loss rules and the general tax law is discussed.

Further, the interplay between the hydrocarbon tax act and the general corporate income tax rules concerning tax losses is discussed.

Read the article here.​

New article on The Nordea Bank Denmark Case (C-48/13)

Anders Nørgaard Laursen has published an article on the Nordea Bank Denmark Case (C-48/13).

The article analyzes the implications of the case and finds that reincorporation of previously deducted losses from a permanent establishment situated in another member state is allowed when certain requirements are fulfilled.

The case also questions whether the Danish international group tax rules are consistent with EU law.

Read the article here.

New Article on Corporate Taxation

Peter Koerver Schmidt has published the article “Corporate Taxation and the International Challenge” discussing the Danish anti-avoidance rules.

The article concludes that the these anti-avoidance provisions often suffer from being quite complex, very broad in scope and open to criticism from an EU law perspective.

Read the article here.

New article summing up regulatory changes

Anders Nørgaard Laursen has published an article on the most considerable regulatory changes in Danish international tax law from August 2013 to July 2014.

The article deals with exit taxation on companies, restricted withholding taxation, administrative guidelines on hiring-out of labour, taking up residence for individuals, and the calculation of personal income tax allowance relaxing taxation on foreign income.

Finally, the article deals with case C-48/13 Nordea Bank Danmark, and the 2014 update of the OECD model tax convention.

Read the article here.