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Reverse Hybrid Structures Attacked by Danish Parliament. No. 6 Vol. 2

2008  Reverse Hybrid Structures Attacked by Danish Parliament No6 Vol 2  June2747151

Published by Bech-Bruun

On 12 June 2008, the Danish Parliament adopted bill L 181 which will be enacted shortly and will potentially affect the Danish tax classification of a number of Danish transparent entities and branches which are treated as non-transparent by their foreign owners. Bill L 181 seeks to obstruct the use of US check-the-box elections for Danish transparent entities (reverse hybrids) by reclassifying such entities into non-transparent corporations for Danish tax purposes.

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