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ARTICLE · 11 APRIL 1995

Taxation of Companies' Shareholdings

DenmarkLitigation, Mediation & Arbitration

This article sets out the main rules on taxation of Danish corporations' sale of shares, etc. It is not intended to cover the rules in detail and the rules on shares in cooperative entities are specifically omitted. Though cooperative entities are commonly used in Denmark, foreign investors are not often found among their shareholders. Unless necessary for the description of other rules, the rules on investment fund certificates in distributing investment funds are also omitted.

Companies, etc. subject to the Act on Capital Gains Tax on Shares

Companies and certain foundations/trusts which are fully tax liable to Denmark at the time of sale are subject to the Act on Capital Gains Tax on Shares. Companies, etc. which are not fully tax liable to Denmark are not subject to the Act on Capital Gains Tax on Shares unless buying and selling shares is part of their ordinary course of business or trade and the shares in question are connected with a permanent establishment in

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