By Arne Riis
The Danish tax authorities on January 25 issued a draft bill that would amend the Danish Tax Assessment Act to adopt the international general antiabuse rule under consideration at the EU and OECD levels and to deal with potential domestic abuses.
The draft bill would introduce:
a new international antiabuse rule denying benefits from tax treaties or the EU
savings tax directive in cases of deemed tax abuse;
a new controlled-foreign-corporation-type rule for trusts; and
limits on the duration of exit tax rulings for post-exit asset or business transfers.