New tax rules in Denmark - CFC taxation and countermeasures against private equity funds

On 1 June 2007, the Danish Parliament adopted Bill L 213 concerning CFC taxation and countermeasures against private equity funds. One purpose of the new legislation is to harmonize Danish corporate taxation in order to secure a solid and competitive corporate tax base in the future. The new tax rules also aim to bring Denmark's CFC regime into compliance with EC law after the 2006 ruling of the European Court of Justice in Cadbury Schweppes (Case C-196/04). The major part of the legislation deals with the limitations on the interest deduction for companies with considerable interest expenses. This article discusses the limitations on the interest deduction as well as the five other parts which comprise the new legislation.