DAC6 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
See MoreDenmark: Ministry of Taxation extends all filing deadlines, including transfer pricing documentation
On 31 March 2020, the Ministry of Taxation announced that all the deadlines of tax filing for the 2019 income year and transfer pricing documentation is postponed until 1 September 2020. Employees with an annual tax assessment due date of 1 May
See MoreDenmark: Government announces a package of tax measures due to COVID-19 impact
On 10 March 2020, the Government announced some tax measures to assist companies in situation of Coronavirus impact. These are given below: Companies with supplies more DKK 50 million are subject to monthly VAT payment. But the
See MoreDenmark: Reminder for transfer pricing documentation submission due date
According to the amended Danish Tax Control Act, companies are required to prepare their 2019 transfer pricing documentation and then submit this no later than 30 June 2020 with a financial year that follows the calendar year. On the other hand,
See MoreDenmark publishes Law and Executive Order to implement DAC6 reporting requirement
On 27 December 2019 and on 31 December 2019 Denmark published Law and Executive Order, simultaneously, for the implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reportable cross-border tax planning arrangements (DAC6). This
See MoreDenmark: National Tax Court publishes a decision on the scope of controlled transaction
On 3 January 2020, the National Tax Court published a decision regarding a Case dealing with controlled transactions that "transactions" also include a provision where there is a capital reduction in a company, which is carried out by a reduction
See MoreDenmark: MLI enters into force
On 1 January 2020, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Denmark. On 30 September 2019, Denmark deposited its instrument of ratification for the
See MoreAmending protocol to the Nordic tax treaty enters into force
On 28 November 2019, the amending protocol to the Nordic tax treaty (Denmark, the Faroe Islands, Finland, Iceland, Norway, and Sweden) was entered into force in respect of Norway and applies from 1 January
See MoreHigh Court rules that the Danish loss-making company could not deduct royalties paid to its Swiss parent
On 28 October 2019, the Eastern High Court of Denmark published a case (Denmark vs Adecco; Case No SKM2019.537.OLR of 4 July 2019) decision and agreed with the tax authority that a Danish loss-making company could not deduct royalties paid to its
See MoreDenmark publishes the Bill no. L 48 on international taxation
On 6 November 2019, the Danish Minister of Taxation published Bill no. L 48 on international taxation. The bill updated the existing PE (permanent establishment) rules, CFC rules and strengthen the Transfer pricing (TP) rules. PE rules: The
See MoreDenmark considers draft Bill to implement DAC6 reporting requirement
On 6 November 2019, the Danish Minister of Taxation published Bill no. L 49 on implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reportable cross-border tax planning arrangements (DAC6). This includes measures to require
See MoreDenmark deposits ratification instrument for MLI
On 30 September 2019, Denmark deposited its ratification instrument for the Multilateral Convention to Implement Tax Treaty Related Measures (MLI) to Prevent Base Erosion and Profit Shifting. The MLI is designed to allow countries to swiftly add to
See MoreDenmark: Draft bill on international taxation submits for public comments
On 12 September 2019, the Ministry of Taxes published a major bill on international taxation. The bill will be subjected to a public hearing and subsequently presented to the Danish Parliament. Interested parties can submit their comments by 10
See More