Denmark Drafts Legislation for Implementation EU Anti-Tax Avoidance Directive Measures

The Danish Ministry of Taxation has reportedly prepared draft legislation for the implementation of the measure of the EU Anti-Tax Avoidance Directive (ATAD1) and the Directive as amended (ATAD2). The measures include:

• The amendment of existing interest deduction restriction rules, including a change of the 80% of EBIT limitation to a 30% of EBITDA limitation, with excess interest expense may be carried forward indefinitely and excess interest capacity carried forward for five years;
• The int…