14 ms·

I strongly doubt it. The corporate tax provisions are stricter than most developed economies. All indexes I've seen have Denmark pretty far down tax haven frien

by drsim 6y ago

I strongly doubt it. The corporate tax provisions are stricter than most developed economies. All indexes I've seen have Denmark pretty far down tax haven friendliness. Genuinely curious on your source.

Erwin 6y ago
There is a type of company structure similar to a limited partnership, but where the ownership was anonymous: https://en.wikipedia.org/wiki/Kommanditselskab https://en.wikipedia.org/wiki/Kommanditselskab That was apparently misused by a relatively small companies abroad, where passing profits through this company would keep the information from the right authorities. Not really sure what happened with the case, new rulesets were applied to combat potential abuse. Another high profile case was the "Danish Bank" (not to be confused with the national Bank of Denmark) which was involved in some huge money laundering in Estonia, potentially allowing as much as 200 billion EUR pass through it without asking too many questions. A report from the Tax Justice Network: https://fsi.taxjustice.net/PDF/Denmark.pdf https://fsi.taxjustice.net/PDF/Denmark.pdf
- drsim 6y ago
  Thank you. I was aware of the money laundering. What Danske Bank did is under investigation for being illegal under 'hvidvaskloven'. Let's see how that goes, but the company and its directors are expected to face consequences. That case has nothing to do with a 'tax haven', unless a pattern is formed and the authorities turn a blind eye. I didn't know about the Kommanditselskab company form. It does appear to have been abused, but I can see this is something the tax authorities are on the case with. Link in Danish to a report from 2016: https://www.ft.dk/samling/20151/almdel/SAU/bilag/165/1619506/index.htm https://www.ft.dk/samling/20151/almdel/SAU/bilag/165/1619506... How possible it is to act as a tax have and how friendly a country is to be used like that is a spectrum. The Tax Justice Network report you linked puts Denmark very low on that ranking and tiny (their word) in volume.
- ThomPete 6y ago
  That's not what I am talking about though. I am talking about the zero tax rate for holdning companies. it's an active strategy by the Danish government.
ThomPete 6y ago
Not for holding companies. It's a well known secret and is a way for the Danish government to lure in large international holdning companies. No sure why people are downvoting me. I'm Danish and I do know the tax system pretty well.
- simongray 6y ago
  It's probably because you're calling Denmark a tax haven without providing any documentation? Denmark is not recognised as a tax haven by any country (that I'm aware of). I'm willing to learn something new, but you are not providing any support for your statements.
  - ThomPete 6y ago
    That doesn't mean you should assume I don't know the difference between Denmark and Holland. Tax haven is not an official title for any country or place but a definition and Denmark is by definition a tax haven for holdning companies. Just because it's not well known doesn't mean it's not a tax haven. That word is quite ambiguous. Most countries have some sort of setup to attract foreign investments. "Back in 1999, Denmark allowed Danish companies to hold shares in foreign subsidiaries. In 2009, the Danish government enacted the Danish Tax Reform Act allowing international corporate investors to use Denmark as a holding company jurisdiction. The 2009 Danish Tax Reform law improved Danish participation exemptions applied to dividends and capital gains realized on the transfer of shares by abolishing the holding periods of one year and three years respectively. Another benefit is the ability to receive dividend payments subject to little or no taxes. Other tax haven jurisdictions often do not provide such benefits. The condition for a no tax status on dividends is that an entity owns at least 25% of the Danish company. PepsiCo and other large international companies have established over 500 Danish holding companies over the past few years. PepsiCo Investments, the PepsiCo Danish Holding Company, is managed from a small Copenhagen office by one tax lawyer. Such international demand created a dynamic holding company industry in Denmark. In essence, Denmark allows the registration of completely tax-free holding companies. Dutch holding companies can receive income from numerous different sources and simply pass them to other corporations in different countries. This is why holding companies are globally famous for their tax free funds “pass through” capabilities." https://www.offshorecompany.com/company/denmark-holding/ https://www.offshorecompany.com/company/denmark-holding/

by drsim 6y ago

Erwin 6y ago

There is a type of company structure similar to a limited partnership, but where the ownership was anonymous: https://en.wikipedia.org/wiki/Kommanditselskab https://en.wikipedia.org/wiki/Kommanditselskab That was apparently misused by a relatively small companies abroad, where passing profits through this company would keep the information from the right authorities. Not really sure what happened with the case, new rulesets were applied to combat potential abuse. Another high profile case was the "Danish Bank" (not to be confused with the national Bank of Denmark) which was involved in some huge money laundering in Estonia, potentially allowing as much as 200 billion EUR pass through it without asking too many questions. A report from the Tax Justice Network: https://fsi.taxjustice.net/PDF/Denmark.pdf https://fsi.taxjustice.net/PDF/Denmark.pdf

drsim 6y ago
Thank you. I was aware of the money laundering. What Danske Bank did is under investigation for being illegal under 'hvidvaskloven'. Let's see how that goes, but the company and its directors are expected to face consequences. That case has nothing to do with a 'tax haven', unless a pattern is formed and the authorities turn a blind eye. I didn't know about the Kommanditselskab company form. It does appear to have been abused, but I can see this is something the tax authorities are on the case with. Link in Danish to a report from 2016: https://www.ft.dk/samling/20151/almdel/SAU/bilag/165/1619506/index.htm https://www.ft.dk/samling/20151/almdel/SAU/bilag/165/1619506... How possible it is to act as a tax have and how friendly a country is to be used like that is a spectrum. The Tax Justice Network report you linked puts Denmark very low on that ranking and tiny (their word) in volume.
ThomPete 6y ago
That's not what I am talking about though. I am talking about the zero tax rate for holdning companies. it's an active strategy by the Danish government.

ThomPete 6y ago

Not for holding companies. It's a well known secret and is a way for the Danish government to lure in large international holdning companies. No sure why people are downvoting me. I'm Danish and I do know the tax system pretty well.

simongray 6y ago
It's probably because you're calling Denmark a tax haven without providing any documentation? Denmark is not recognised as a tax haven by any country (that I'm aware of). I'm willing to learn something new, but you are not providing any support for your statements.
- ThomPete 6y ago
  That doesn't mean you should assume I don't know the difference between Denmark and Holland. Tax haven is not an official title for any country or place but a definition and Denmark is by definition a tax haven for holdning companies. Just because it's not well known doesn't mean it's not a tax haven. That word is quite ambiguous. Most countries have some sort of setup to attract foreign investments. "Back in 1999, Denmark allowed Danish companies to hold shares in foreign subsidiaries. In 2009, the Danish government enacted the Danish Tax Reform Act allowing international corporate investors to use Denmark as a holding company jurisdiction. The 2009 Danish Tax Reform law improved Danish participation exemptions applied to dividends and capital gains realized on the transfer of shares by abolishing the holding periods of one year and three years respectively. Another benefit is the ability to receive dividend payments subject to little or no taxes. Other tax haven jurisdictions often do not provide such benefits. The condition for a no tax status on dividends is that an entity owns at least 25% of the Danish company. PepsiCo and other large international companies have established over 500 Danish holding companies over the past few years. PepsiCo Investments, the PepsiCo Danish Holding Company, is managed from a small Copenhagen office by one tax lawyer. Such international demand created a dynamic holding company industry in Denmark. In essence, Denmark allows the registration of completely tax-free holding companies. Dutch holding companies can receive income from numerous different sources and simply pass them to other corporations in different countries. This is why holding companies are globally famous for their tax free funds “pass through” capabilities." https://www.offshorecompany.com/company/denmark-holding/ https://www.offshorecompany.com/company/denmark-holding/