On 3 June 2021, the Danish Parliament approved a Bill L 89 to amend the controlled foreign company (CFC) rules with the purpose of bringing them in line with the EU Anti-Tax Avoidance Directive (ATAD). The major mechanism in the Danish CFC rules remains the same and ensures that a Danish parent company is taxed on income earned in a foreign subsidiary. The objective remains the same as well, as the rules are intended to prevent financial income from being shifted to foreign subsidiaries away from the Danish parent company. Simultaneously, the rules must comply with EU law and specifically with the fundamental freedoms. It enters into force from 1 July 2021.
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