Reclassification of Danish Transparent Entities

The Danish Minister of Taxation has in April 2008 submitted to the Parliament a bill (the "Bill") regarding reclassification of Danish transparent entities and branches in certain situations.

If adopted, the Bill may cause significant tax costs for current structures and affect the future use of Danish transparent entities for tax planning purposes. The Bill proposes Danish transparent entities (either incorporated in Denmark or having corporate seat of effective seat of management in Denmark) and Danish registered branches of foreign entities to be reclassified as non-transparent for Danish tax purposes.