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23 March 2018 Danish Government publishes bill on tax exempt cross-border reorganizations On 23 March 2018, the Danish Minister of Taxation published bill No. L 207 regarding tax exempt cross-border reorganizations where a Danish company is the liquidated company. The reorganization may be a merger, a division, or a transfer of assets. According to the bill such a reorganization cannot have retroactive effect prior to the date when the reorganization is finally approved by the companies covered by the merger. The purpose of the bill is to prevent situations where a Danish company enters into a reorganization with a foreign company and no permanent establishment will remain in Denmark after the reorganization. Hence, under existing law, this might mean that Denmark must abstain from levying tax on the taxable income of the Danish company for a period prior to the approval of the merger. If enacted by Parliament, the law will have effect for reorganizations that are finally approved by one of the companies on 23 March 2018 or thereafter.
Document ID: 2018-5459 |
