New anti-avoidance rules in Denmark target reverse hybrids and convertible bonds

In June 2008, Denmark adopted anti-avoidance rules aimed at cross-border structures using reverse hybrids and convertible bonds to reduce tax liability. This article discusses the new rules pertaining to reverse hybrids, including the reason for the new rules, the entities caught by them and the consequences for the entities caught by the new rules. Regarding convertible bonds, the article outlines the tax planning opportunities under the former rules and describes the new anti-avoidance rule and its effect.