Emnet for denne afhandling er dansk skatteretlig CFC-lovgivning. Denne form for lovgivning går kort fortalt ud på, at aktionæren i et selskab under særlige omstændigheder skal medregne en andel af selskabets indkomst til sin egen skattepligtige indkomst, selvom selskabet ikke har udloddet...

As a result of the OECD/G20 project on base erosion profit shifting as well as the adoption of the EU anti-tax avoidance directive, many countries have recently introduced or strengthened general anti-avoidance rules (GAARs) in their tax treaties and domestic tax legislations. Arguably, such...

The authors analyse the current (lack of) possibilities for user-jurisdictions to tax the value generated by the increased use of digital intermediary platforms. Focus is on analysing the possibilities for user-jurisdictions to tax the remuneration received by a foreign enterprise owning a...

The article analyzes whether the investment in a private equity fund may create a permanent establishment (PE) for foreign investors. The analysis is divided into two main parts, as the question of creating a PE for the foreign investors is considered with respect to both the main PE-rule and...

It is argued that at the higher degree of economic integration across borders and the international trend towards a reduction of corporate income tax rates have had a significant impact on the Danish corporate tax regime in recent years. Accordingly, during the last ten years the Danish...

This contribution analyzes the origin and creation of Denmark's tax treaty network in a historical perspective. The development of the Danish treaty network is studied through an international perspective and by discussing a number of milestone events. It is concluded that the general tendency...

The authors analyse the current (lack of) possibilities for user-jurisdictions to tax the value generated by the increased use of digital intermediary platforms. Focus is on analysing the possibilities for user-jurisdictions to tax the remuneration received by a foreign enterprise owning a...

The author discusses whether the EU Anti-Tax Avoidance Directive (ATAD) may be expected to promote tax fairness and thereby contribute to increased sustainability of the international tax regime. A legal (juridical) approach to tax fairness is followed, which entails that the provisions of the...

The author explores whether legal pragmatism may function as a useful and adequate explanatory model for the case law on tax avoidance unfolding in the Danish Supreme Court. In doing so, the underlying ideas of philosophical and legal pragmatism are initially re-visited while the general...