Tax implications of advisory services for non-established entity in cross-border acquisition transaction.

• H1, a 100% owned subsidiary of H2, was invoiced for costs related to the acquisition of shares in G2
• H1 was a Danish limited liability company with no employees, and its management was located in a third country
• H1 was not a taxable person and was not established in Denmark
• H2, the supplier of services for the share acquisition, was a taxable person established in a third country
• The place of supply for H2’s services to H1 was determined to be in the third country, not Denmark
• This meant that the services were not subject to VAT in Denmark, and H1 was not liable for payment in connection with the purchase.

Source: info.skat.dk

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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