ARTICLE · 05 SEPTEMBER 2023

Beneficial Ownership: Final Judgments In "Danish Cases" - Interest

Kromann Reumert

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On 4 May 2023, the Danish Supreme Court gave final judgments in the last two of the so-called "Danish Cases". Ruling on interest payments and accruals to group companies...

DenmarkTax

Birgitte Broholm Hasselriis

Lenni Hangaard Jensen

On 4 May 2023, the Danish Supreme Court gave final judgments in the last two of the so-called "Danish Cases". Ruling on interest payments and accruals to group companies in Sweden and Luxembourg, the Supreme Court held in favour of the Danish Ministry of Taxation.

The focal point in the "Danish Cases" is the "beneficial owner" quality of EU resident companies receiving dividend or interest payments or accruals from their Danish resident group companies, and whether the Danish companies should have withheld tax on such payments and acted negligently in not withholding. On 9 January 2023, the Supreme Court gave judgment on dividend withholding tax.

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