Corporate Taxation and the International Challenge

Nordic Tax Journal, Issue 2, pp. 113-131, 2014, DOI: 10.1515/ntaxj-2014-0021

19 Pages Posted: 16 Dec 2018 Last revised: 10 Jan 2019

Date Written: 2014

Abstract

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 statutory corporate tax rate has been lowered further, while several government actions at the same time have been taken in order to combat international tax avoidance and evasion. As a result, new anti-avoidance provisions have been introduced and some of the older anti-avoidance provisions have been tightened in order to prevent base erosion and profit shifting. Thus, to some extent Denmark has already tried to address a number of the key pressure areas mentioned in the recently published OECD BEPS report, such as international mismatches in entity and instrument characterization, the tax treatment of related party debt financing, transfer pricing and the effectiveness of anti-avoidance measures. However, the article concludes that these anti-avoidance provisions often suffer from being quite complex, very broad in scope and open to criticism from an EU law perspective.

Keywords: Danish corporate taxation, base erosion and profit shifting, antiavoidance measures, EU law

Suggested Citation

Koerver Schmidt, Peter, Corporate Taxation and the International Challenge (2014). Nordic Tax Journal, Issue 2, pp. 113-131, 2014, DOI: 10.1515/ntaxj-2014-0021 . Available at SSRN: https://ssrn.com/abstract=3290051

Peter Koerver Schmidt (Contact Author)

Copenhagen Business School - CBS Law ( email )

Porcelaenshave 18B, 1
Frederiksberg 2000
Denmark

Register to save articles to
your library

Register

Paper statistics

Downloads
12
Abstract Views
351
PlumX Metrics