On 4 October 2023, the Danish Ministry of Finance (MoF) issued a draft bill for the implementation of the Pillar 2 global minimum tax rule in accordance with EU Council Directive 2022/2523 of 14 December 2022. The proposal seeks to establish a minimum tax threshold of 15% for multinational enterprises (MNEs) with annual consolidated revenues of at least EUR 750 million in at least two of the past four fiscal years. This will be achieved through the introduction of the Pillar 2 income inclusion rule (IIR) and the undertaxed payment/profit rule (UTPR).
This draft bill will come into effect and apply to fiscal years starting on or after 31 December 2023, with the exception of the UTPR which will apply to fiscal years starting on or after 31 December 2024.
