Denmark issues guidance on DAC7 reporting requirements
On 2 November 2022, the Danish Customs and Tax Administration published guidance on DAC7 registration and reporting requirements for digital platform operators under Council Directive (EU) 2021/514. This directive has been published on 25 March
See MoreIMF Report Considers Fiscal Policy in Denmark
On 9 May 2022 the IMF issued a report following discussions with Denmark under Article IV of the IMF’s articles of agreement. The economic recovery is likely to continue in Denmark, with the lifting of restrictions introduced during the
See MoreDenmark introduces new filing requirements for TP documentation
Recently, the Danish Ministry of Finance introduced an obligation to file a transfer pricing documentation (TPD) with the Danish Tax Authorities on an annual basis. For the financial years beginning on or after 1 January 2021, the new law requires
See MoreDenmark amends the transfer pricing documentation rules
On 31 January 2022, the Danish Ministry of Finance issued updated guidance regarding amendments to the transfer pricing rules requiring the submission of the transfer pricing documentation within 60 days of the due date for filing the tax return,
See MoreDenmark approves the bill to relax rules on TP documentation
On 25 November 2021, the Danish Parliament passed Draft Law No. L7, which largely abolishes the obligation to include domestically, controlled transactions in the Transfer Pricing Documentation (TP). The draft law also specifies the requirement to
See MoreDenmark: Parliament considers bill to relax rules on TP documentation
On 6 October 2021, the Danish parliament is taking into account draft bill L 7, which proposed an amendment to the Danish Tax Control Act in order to relax the documentation requirements for transfer pricing for purely Danish transactions. The
See MoreDenmark plans to make permanent the tax incentives for R&D
On 7 September 2021, the Danish government proposed to make permanent the current temporarily increased deduction for research and development expenses of companies under an economic and social plan. An increased deduction of 130% of R&D
See MoreDenmark presents Budget for 2022
On 30 August 2021, the Minister of Finance presented the government's budget proposal for 2022. With its proposal for the Finance Act 2022, most of the measures presented focus on easing the country's transition out of the crisis and include a
See MoreDenmark proposes to reduce the TPD obligation for purely Danish transactions
On 23 June 2021, the Ministry of Finance submitted a draft bill for consultation. The bill proposed an amendment to the Danish Tax Control Act in order to relax the documentation requirements for transfer pricing for purely Danish transactions. It
See MoreDenmark: Government publishes a Bill to amend Tax Control and Assessment Act
On 23 June 2021, the Ministry of Taxation proposed a draft Bill to amend the Tax Control Act and the Tax Assessment Act (Competence for approval of the information form, etc., adjustment of the disclosure deadline for legal entities, accounting in
See MoreDenmark: OECD publishes latest MLI position on arbitration reservation
On 29 June 2021, the OECD published a document, which contains the consolidated list of reservations and notifications made by the Kingdom of Denmark upon deposit of the instrument of ratification pursuant to Articles 28(5) and 29(1) of the
See MoreDenmark: Parliament approves ATAD amendments to CFC rules
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
See MoreDenmark: Ministry of Taxation launches a public consultation regarding CFC rules
On 23 April 2021, the Ministry of Taxation announced a public consultation for amending a draft Bill L 89. This Bill proposes for an Act amending the Corporation Tax Act and the Capital Gains Tax Act (Implementation of the minimum requirements of
See MoreDenmark: Supreme Court makes a decision on a case regarding TP documentation
On 26 April 2021, the Danish Supreme Court issued its decision in a landmark transfer pricing case: Denmark v Tetra Pak Processing Systems A/S , in which a Danish company (Tetra Pak) that produced and sold plants for manufacturing ice cream. The
See MoreDenmark: MOF withdraws its litigation in significant transfer pricing cases
12 April 2021 On 25 March 2021, the Danish Ministry of Taxation has dismissed a case: SKM2018.511.LSR due to expectations that the company would succeed the case. The Ministry’s message that it admits defeat and will refrain from spending
See MoreDenmark: 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
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