(a) The rate is 0% for royalties paid for copyrights of literary, artistic or scientific works, including cinematographic films, and for the use of, or the right to use, industrial, commercial or scientific equipment.
Denmark passed significant tax reform in May, including the abolition of the so-called three-year rule where companies were tax exempt on gains on shares after holding them for three years.The reform introduced a distinction between shares in group related ...
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Denmark passed significant tax reform in May, including the abolition of the so-called three-year rule where companies were tax exempt on gains on shares after holding them for three years.
The reform introduced a distinction between shares in group related companies, where the company owns at least 10% of the share capital, and portfolio shares where the shareholding is less than 10%. Shares in group related companies will, as a general rule, be tax exempt and losses on these shares will also not be deductible, whereas gains and losses on portfolio shares will considered to be taxable income.
The package raised taxes on customs and duties to fund a reduction in personal taxes.
Funds taxation has also changed. One commentator said "Parliament doesn't like investment funds and hasintroduced a harsh law," The rules have changed and taxes are now higher.
The tax authorities have a very aggressive attitude to transfer pricing as they look to protect revenues. Many commentators expect the number of audits to increase which will lead to an increase in litigation.
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