Denmark

Abuse of rights, Beneficial ownership, Denmark, ECJ, Intertax, Principal purpose test, Switzerland

(Tax Policy Center, University of Lausanne; Danon, Lausanne)/ /Leave a comment

Analysis of the ECJ judgments, reading by national courts, and impact on tax treaty practice Authors: Robert Danon,[1] Daniel Gutmann,[2] Margriet Lukkien,[3] Guglielmo Maisto,[4] Adolfo Martín Jiménez,[5] Benjamin Malek[6]   (Forthcoming: Intertax, vol. 49, 2021, issue 6/7) Since they were delivered in 2019, the judgments of the ECJ in the Danish cases have been widely…

Denmark, MLI, OECD, Permanent Establishments

(International tax professional)/ /Leave a comment

Denmark accepted all MLI articles dealing with PEs, but what does that actually mean?  Reading the MLI itself leaves one somewhat bewildered, being thrown back and forth between a variety of articles and options.  Reading the instrument of ratification, does not necessarily help: it tends be a collection of long list of countries with treaty…