Consequently no withholding tax is payable on dividends distributed from a Danish holding company to a foreign parent company. Furthermore, there is no tax on dividends received by a Danish holding company from a foreign subsisdiary. The rules contained no restrictions on the jurisdictions of the foreign parent or subsidiary. Accordingly, structures could be established even including zero tax companies as parent or subsidiary. There will be no change regarding inbound dividends.
Taxable income comprises gross income less the costs of earning, securing and maintaining it.
The starting point of determining taxable income is the profit or loss shown by the company s statutory financial statement, adjusted for items such as exempt income, disallowable expenditure, and losses carried forward, etc. Deductible costs include those incurred on investigating a new market or expanding an existing business. In addition, costs incurred on lawyers and accountants in establishing or expanding a business may be fully deducted in the year in which they are incurred. Merger or reorganisation costs incurred are generally also deductible. Legal expenses incurred on the acquisition of fixed assets form part of the depreciable cost of such assets.