On 13 December 2023, the Denmark Official Gazette published Law No.1535 enacting EU Council Directive 2022/2523 into domestic law, which aims to establish a global minimum level of taxation for multinational enterprise (MNE) groups and large domestic groups within the European Union. The law applies a minimum tax rate of 15% to MNE groups with annual consolidated revenue exceeding €750 million in at least two of the past four fiscal years. Adhering to the Directive and OECD Model Rules, the regulations establish an Income Inclusion Rule (IIR), Undertaxed Profit Rule (UTPR) and qualified domestic top-up tax (QDTT).

This law comes into force on 31 December 2023 for the mainland of Denmark. The Faroe Islands and Greenland are exempt from its application.