►The section covers◄

►
• Rule
• How is the relief implemented 
◄

►Life insurance companies liable to taxation under SEL can, when determining the PAL tax under Section 8 of PAL, deduct tax paid to a country other than Denmark and tax paid to the Faroe Islands or Greenland under Section 20(1) of PAL. ◄

►This only applies, however, if the life insurance company has not made any deductions in the tax under SEL.◄

►The companies are free to choose whether they wish to deduct the foreign tax from the PAL tax or the tax under SEL.◄

How is the relief implemented

►In the determination of PAL tax, relief is granted for tax paid to a country other than Denmark or tax paid to the Faroe Islands or Greenland under Section 33 of LL. See Section 20(1) of PAL. ◄

►Irrespective of whether PAL or SEL is applied, relief for foreign tax in the Danish tax is calculated in accordance with the general rules on credit set out in Section 33 of LL. ◄

See also

►See Assessment Guide 2008, section S.E.2 Tax reductions.◄

Note

►The purpose of taxation under PAL is to tax the yields that are to be paid to the policyholders, whereas the purpose of taxation under SEL is to tax the funds which accrue to the owners of the company◄.