What we're good at

International Tax

Enhancing operational efficiency: Structuring of cross-border operations to mitigate tax risks and tax leakages.

International tax refers to the set of rules, regulations, and principles governing taxation across borders. It deals with how countries tax income, profits, transactions, and assets that involve more than one jurisdiction. International tax matters arise when businesses engage in cross-border activities such as trade, new market entries, investment, or employment in multiple countries. Key aspects of international tax include relief from double taxation, double taxation treaties allocation, structuring transactions and business operations, etc. Overall, international tax is a complex and dynamic field that requires a deep understanding of both domestic and international tax laws, as well as the ability to direct the interaction between them.

  • Permanent establishments in Denmark including also activities in Denmark’s Exclusive Economic Zone (EEZ)
  • Danish tax qualification of foreign entities, transactions, etc.
  • Structuring and legal entity rationalization
  • Danish withholding tax positions for dividends, liquidations proceeds, interest, royalties, etc.
  • Flow of funds
  • Refinancing
  • Cross-border and Danish taxable and tax-exempt restructurings
  • Cross-border intercompany transfers and business restructurings
  • Interest deduction limitation rules
  • Hybrid mismatch
  • CFC taxation
  • Final tax-losses abroad
  • Danish international tax consolidation
  • DAC6
  • DAC7
  • Pillar 2