Corporate tax implications of Denmark's unilateral termination of its tax treaties with France and Spain

Denmark terminated its tax treaties with France and Spain effective 1 January 2009. This means, among other things, that each country will tax the income in question according to its domestic tax rules, which could result in a higher effective tax rate or double taxation in some cases. This article examines the corporate tax consequences of the terminations for Danish companies with activities in or payments from France or Spain and for French and Spanish companies with activities in or payments from Denmark.