Denmark Tax Agency Clarifies Tax Liability, Capital Gains in Corporate Restructuring Through Liquidation

Sept. 29, 2025, 5:00 AM UTC

The Danish Customs and Tax Administration Sept. 24 posted online Tax Council Binding Answer No. SKM2025.536.SR, clarifying the tax liability for merging companies, and capital gains for shareholders, upon a corporate restructuring through liquidation. The taxpayer, a company, intended to merge with and liquidate its wholly-owned subsidiary, by discontinuing the subsidiary’s activities and transferring all of its assets and operations to the taxpayer. The taxpayer sought clarification regarding its tax liability, and capital gains tax for the shareholders. The Tax Council found that: 1) the tax liability of the merging companies couldn’t be confirmed without self-reporting, therefore a full tax ...

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