David Munch, Ydelser

Danish High Court Decision on International Holding Structure

Derivatives & Financial Instruments - 2012

"The author provides a summary of a recent decision of the Eastern High Court on taxation of dividends at source in the context of an international holding structure. The scope of the summary focusses on the international tax aspect of the case only." (from the table of contents)

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Taxation of Basel III-Compliant Instruments

Derivatives & Financial Instruments – 2012

The article comments on the following questions posed by IBFD: 1) Debt/Equity Characterization for Tax Purposes, 2) Deductibility of Coupon for Corporate Income Tax Purposes, 3) Possible Withholding Taxes on Coupons, 4) Recognition of Income and Expense, 5) Tax Treatment of the Conversion versus Write-Down, 6) Stamp Duties/Capital Taxes upon Issue and/or Conversion and 7) Transfer Pricing Consequences of Intercompany Financing.

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Taxation of Bonds and Other Financial Instruments Held by Individuals

Derivatives & Financial Instruments - 2010

"This article is in line with two previous articles published in this journal in 2009... The article concerns Bill 112, which passed in the Danish parliament on 1 June 2010 (Act 724 of 25 June 2010)." (from the table of contents)

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