Denmark gazettes consolidated Minimum Taxation Act under Executive Order No. 1089/2025, aligning with OECD guidance and EU Directive 2022/2523
Denmark has published the consolidated Minimum Taxation Act through Executive Order No. 1089/2025 on 10 September 2025, following amendments made by Act No. 750/2025 effective from 1 July 2025.
The update aligns Danish rules with OECD guidance and clarifies how the minimum tax applies alongside international joint taxation and deferred taxes.
The Act adopts OECD guidance from June 2024 and January 2025 and ensures consistency with EU Directive 2022/2523. Key updates cover the allocation of taxes within international joint taxation, measures to prevent double taxation on recaptured foreign losses and restrictions on allocating Danish tax to passive income.
Additional changes introduce rules for securitization entities, allow companies to exclude certain deferred tax liabilities from covered tax calculations for up to five years, and define how pre-transition deferred tax assets and liabilities are treated when calculating effective tax rates.
Earlier, Denmark’s parliament approved Bill L 194A, amending the Minimum Taxation Act, Corporate Tax Act, and other laws on 3 June 2025.
