Denmark: Tax Treatment of US LLC owned by Danish APS

Oct 29, 2023
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United States
I have a question about the following scenario, from the viewpoint of Danish tax law (not US tax law):

1. LLC ABC is registered in USA
2. LLC ABC is owned 100% by Danish APS (company) which is a non-operational holding company. It has the default pass-through taxation.
3. LLC ABC receives income from non-Danish sources.
4. That income passes through to the Danish APS, due to pass through taxation, but it is not a dividend.

Does LLC ABC pay taxes in Denmark? Or is it excluded because it is not Danish-source income?

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