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The Danish conduit cases: a landmark ruling on withholding tax and abuse of rights

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Private equity funds have made extensive use of European holding and finance companies in acquisition structuring. In the Danish conduit cases, the CJEU has found that the establishment of holding companies in European jurisdictions can amount to an abuse of rights in some circumstances. Abusive holding companies will not qualify for withholding tax exemption under the Parent-Subsidiary Directive or the Interest and Royalties Directive, even where exemption would otherwise apply under domestic rules.

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