Denmark has enacted Law No. 684, published on 11 June, 2024, introducing amendments to align the Minimum Taxation Act with the OECD’s model rules and guidelines for the Pillar Two global minimum tax.
The law includes protection rules to prevent groups from exploiting transitional provisions to avoid taxation and simplifies calculation rules for applying the permanent exemption provision in line with the OECD’s December 2023 guidelines.
Additionally, Law No. 684 updates Denmark’s list of jurisdictions subject to defensive measures for non-cooperative tax practices to match the EU’s list. This update removes the Bahamas, Belize, the Seychelles, and the Turks and Caicos Islands from the list.
The law will take effect on 1 July, 2024, with the Minimum Taxation Act amendments applicable to fiscal years starting on or after 31 December, 2023.
