Denmark Tax Agency Clarifies Tax Treatment of Dividends, Interest Paid to German Alternative Investment Fund

The Danish Customs and Tax Administration March 4 posted Tax Council Binding Answer No. SKM2026.119.SR, clarifying the tax treatment of dividends and interest paid to a German alternative investment fund (AIF). The taxpayer, a German AIF, intended to acquire all shares in a Danish property company and provide loans to it. The taxpayer sought clarification regarding whether dividends from the Danish company and interest on the shareholder loan would be subject to limited tax liability in Denmark, and whether the general anti-avoidance rule applied. Upon review, the Tax Council found that: 1) the taxpayer was an independent taxpayer and the ...