Les clauses restrictives de la convention fiscale franco-danoise font obstacle à ce que les renseignements échangés entre les administrations de chaque Etat soient communiqués à un contribuable
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Une société a fait l'objet d'une notification de redressement en raison de l'omission de déclaration de recettes correspondant à des prestations de services facturées à une société danoise, dont le capital est détenu par une société française. L'absence de comptabilisation de ces prestations dans les résultats imposables, a été révélée aux services fiscaux dans le cadre des échanges de renseignements entre les administrations française et danoise. La cour administrative d'appel de Paris a estimé, le 21 décembre 2007, que la société n'était pas fondée à arguer de l'irrégularité de la procédure d'imposition au motif que ces renseignements ne lui avaient pas été communiqués. En effet, la convention fiscale franco-danoise du 8 février 1957 prévoit que les renseignements échangés entre les administrations française et danoise conservent un caractère secret...
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