A Danish executive order No. 1133 dated 27 August 2016 was issued to provide detailed rules on notice requirements and on how the CbC report must be completed. The executive order was effective from 1 September 2016.

Notification requirements:

i) For corporate groups required to file CbC reports, notification must be provided in a digital form to the Danish tax authorities (SKAT) no later than the end of the income year for which the CbC report must be submitted.

-If the ultimate parent company is a Danish company, the group company filing the CbC report must be identified in the notification.

-If the ultimate parent company is not a Danish company, the notification to SKAT must include information on what group company is required to file the CbC report and in what tax jurisdiction the company in question is the resident.

ii) The information concerning the identity of the group company must include its “full” name, address, tax jurisdiction, and company number (CVR). Foreign companies must provide a tax identification number for the tax jurisdiction in question.

iii) Going forward, SKAT must be notified if there is a change in circumstances no longer requiring the submission of the CbC report (in other words, the requirements for CbC reporting cease to exist).

CbC reporting requirements:

With the new executive order, the Danish requirements have been aligned with the requirements and definitions set forth in Annex III to chapter V in OECD’s “Guidance on Transfer Pricing Documentation and Country-by-Country Reporting.” The submission of the CbC report must be made digitally, according to SKAT’s instructions.