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Denmark Clarifies VAT Treatment for LLC-to-Partnership Restructuring and Bonus Payments

A recent Danish Tax Council ruling (SKM2025.569.SR) clarified the VAT treatment of a corporate restructuring for a consulting and auditing firm. The plan involved transferring all assets and liabilities from a Danish LLC to a new partnership, with employees holding interests through holding companies. Crucially, the Tax Council determined that the partnership and its owners could not be considered a single taxable person for VAT purposes. Additionally, bonus payments made to the partnership owners were ruled to be exempt from VAT because they were not considered consideration for supplies.

Source: news.bloombergtax.com

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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