The Danish tax authorities (SKAT) on 9 December 2016 announced that country-by-country (CbC) notifications must be submitted electronically and in a standardised format on Form 05.034. The form contains instructions both in English and Danish, and can be found on the Danish Tax Administration’s homepage. The file should be sent as a pdf attachment via the DTA’s portal “TastSelv.”

Identical filing format

The notification is required for all Danish companies and permanent establishments that form part of a group subject to prepare and submit the CbC report. For companies covered by Danish joint taxation, only the “administration company” is required to complete the CbC notification form and provide the form to SKAT.

However, Entities that already have provided notification via post or e-mail and have received confirmation of receipt are not required to send a new notification for this year.

Notification requirements:

-The corporate groups also required to file CbC reports, the timing of the notification requirement in Denmark is determined based on the local company’s fiscal year.

-Notification must be provided to SKAT no later than the end of the fiscal year for which the CbC report is submitted.

-Information in the notification concerning the identity of the group company filing the CbC report must include the following information:

  1. Companies full entity name;
  2. Companies full address;
  3. Tax jurisdiction; and
  4. CVR – number of the company.

If the filing company is a non-Danish resident, the information must include a tax identification number for the tax jurisdiction in question. SKAT must also be notified if there is a change in circumstances no longer requiring the submission of the CbC report.

Furthermore, failure to comply with the notification requirement may result in sanctions in the event that it leads to the DTA’s subsequent failure in obtaining or receiving the country-by-country report.