Danish Branch Report on Taxation of Foreign Passive Income for Groups of Companies – Prepared by Peter Koerver Schmidt

The report has been prepared for the 67th Congress of the International Fiscal Association that takes place in Copenhagen from 25-30 August 2013. In the report the Danish rules of relevance for taxation of foreign passive income are presented. The focus is on the Danish CFC-rules, i.e. the rules on Controlled Financial/Foreign Companies. In connection to this the relationship between the Danish CFC-rules and EU-law/tax treaties are discussed. The report has been published in Cahiers de droit fiscal international, 2013, vol. 98a, p. 259-278.