26 February 2018 Danish Government proposes amendments to corporate taxation rules The Danish Minister of Taxation (the Minister) published draft legislation on February 26, that would amend Danish corporate taxation as follows: (i) Provide an exemption from permanent establishment (PE) taxation for investments in Danish private equity funds; (ii) Prevent the economic double taxation of dividends received by Danish PEs; (iii) Relax the taxation of foreign pension funds' investments in Danish real estate; (iv) Relax the thin capitalization rule; and (v) Close the loophole in the dividend recharacterizing rule (section 2 D). On February 23, the Minister also proposed an increase in the tax deduction for research and development (R&D) expenses. The proposals are expected to be enacted by June 2018. Document ID: 2018-0424 |