David Munch, Ydelser

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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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Incitamentsordninger - aktieordninger og aftalelovens § 36

Revision & Regnskabsvæsen – 2012

"In the light of the decision of the Danish Supreme Court, “U.2011.2654H”, concerning the application of article 36 of the Act on Agreements in a case concerning the acquisition of shares where the shares should be sold back, if the employment ceased, advokat David Munch writes about the consequences of the decision and general perspectives for incentive schemes. It is the first time that this article has been applied in connection with share schemes. It is a fairly complicated area of law and the decision of the Supreme Court was not unanimous. ..." (from the reference to the article in connection with the table of contents (unofficial translation))

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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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