New article on CFC rules by assistant professor Peter Schmidt
The article “Die dänischen CFC-Vorschriften für Gesellschaften und ihre Vereinbarkeit mit Gemeinshafts- und Abkommensrecht" is written by Peter Schmidt who obtains the title of assistant professor 1st of July this year.
The article was published in the latest issue of “Internationales Steuerrecht” and has been prepared together with Markus Schneider (PhD student and tax advisor from Bonn).
The purpose of the article is to give a brief introduction to the Danish legislation concerning Controlled Foreign Corporations (CFC rules) and to highlight the main similarities and differences between the German and Danish CFC rules. Moreover, the article provides insight into the debate on whether the current Danish CFC-regime should be considered in breach of EU law and/or Denmark’s tax treaties.