Denmark: Government submits a draft Bill to amends various Acts
On 25 February 2021, the Government submitted a draft Bill, L 178, in the Parliament, which is a proposal for an Act amending the Depreciation Act, the Tax Assessment Act, the Pension Returns Taxation Act and the Sulfur Tax Act. The draft bill
See MoreDenmark: Government introduces new anti-avoidance rule
On 27 January 2021, the Government submitted a draft bill L 150, which proposes to introduce two defensive measures against the countries on the EU list of non-cooperating tax jurisdictions. According to the proposal, the Law will enter into force
See MoreDenmark: Court supports a decision on a case regarding intra-group deposits
On 18 January 2021, the National Tax Tribunal uphold a decision on a case of SKM2021.33.LSR regarding intragroup deposits with a group treasury entity, mentioning the taxpayer’s flawed documentation and differences in the interest rates charged
See MoreDenmark: Parliament temporarily increases R&D deduction
In the late December 2020, the Parliament published Legislation to temporarily increase the deduction for research and development (R&D) up to 130%. The legislation notifies the following issues: Company conducts R&D activities for
See MoreDenmark: Government publishes an Act to set the timeline for filing TP documentation
On 9 December 2020, the Ministry of Taxation Officially published L 28 Proposal for a Law No. 1835 of 8 December 2020 to establish the timeline for filing transfer pricing (TP) documentation and amends the Corporation Tax Act and various other acts
See MoreDenmark: Parliament adopts a Law regarding transfer pricing
On 3 December 2020, the Parliament adopted the draft Bill No. L 28, which proposes to implement the OECD's recommendations on permanent establishment, so that the Danish rules are brought into line with the latest international standards. The
See MoreDenmark: Ministry of Trade and Industry announces fixed costs compensation scheme
On 12 November 2020, the Ministry of Trade and Industry published executive Orders, BEK no. 1604 and BEK no. 1606, which extended the fixed costs compensation scheme to support the companies affected during coronavirus pandemic. The two Executive
See MoreDenmark: High Court makes a decision against tax authority’s TP approach
On 5 October 2020, the High Court made a decision on a case entitled “Denmark vs. Shoe Group A/S” against the tax administration’s transfer pricing (TP) approach. The tax administration of Denmark used various theories to claim that a
See MoreDenmark: National tax court clarifies TP documentation rules for intergroup companies
On 24 September 2020, the Danish Tax Administration published a Decision No. SKM2020.387.LSR, clarifying the transfer pricing documentation requirements for a change of business structure within a group company. The case concerns a Danish
See MoreDenmark: Tax Minister announces to exempt nonresident charitable organizations from WHT
On 14 September 2020, the Tax Minister announced that Government has a plan to release a Bill in December 2020 regarding the exemption of on non-resident charitable organizations from Danish withholding tax (WHT) on portfolio dividends. At present,
See MoreDenmark: Government presents draft Budget for the year 2021
On 31 August 2020, the Government presented the draft Budget 2021 or Finance Bill 2021 to the Parliament. The Government's proposal for a Finance Act for 2021 is marked by the corona pandemic, which continues to create both health and economic
See MoreDenmark: Ministry of Taxation publishes a Bill regarding deduction for R&D expenses
The Ministry of Taxation has recently published a draft Bill, which provides an increase in the allowed deduction of R&D expenses up to 130% for the 2020 and 2021 tax years to give support to companies and investment during COVID-19 pandemic.
See MoreDAC6 Updates: Optional deferral of DAC6 reporting deadlines
On 24 June 2020, the European Council reached agreement on an optional 6-month postponement to the reporting deadlines for relevant taxpayers under EU Directive 2018/822 (DAC6), and a delay to the exchange of information under
See MoreDenmark: Tax authority extends the initial DAC6 reporting by six months
On 29 June 2020, the Tax authority updated guidance to announce that the primary deadline of reporting cross-border arrangements (DAC6) are extended by six-months. The specific deadlines are declared through an Executive Order (BEK) No. 1049 of 29
See MoreDenmark: Supreme Court makes a decision regarding royalties and TP documentation
On 25 June 2020, the Supreme Court made a decision on a case, entitled “Denmark vs. Adecco A/S”, in favor of Danish company, Adecco, and its Swiss parent company in a dispute involving the deductibility of royalties and the sufficiency of
See MoreDenmark: Government proposes to extend the payment deadline of wage tax and VAT
On 28 May 2020, the Ministry of Taxation issued a release where the Government and the economic group proposed to extend the payment deadlines for wage tax, labor market contributions, and VAT. With the proposal, Danish companies can look
See MoreDenmark: Tax authority publishes a guide regarding DAC6
On 17 April 2020, the tax authority published a guide regarding the mandatory disclosure and exchange of cross-border tax arrangements (DAC6) and will enter into force as from 1 July 2020. The guidelines describe the scope of the reporting
See MoreDenmark: President announces to postpone a Bill for amending CFC rules
On 15 April 2020, the Prime Minister informed the president of the parliament that some of proposed legislation need to be postponed during COVID-19 pandemic. One of the proposed legislation is Bill L48, which provides the transpose in existing CFC
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