Denmark: Parliament temporarily increases R&D deduction

07 January, 2021

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

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Denmark: Government publishes an Act to set the timeline for filing TP documentation

14 December, 2020

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

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Denmark: Parliament adopts a Law regarding transfer pricing

10 December, 2020

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

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Denmark: Ministry of Trade and Industry announces fixed costs compensation scheme

26 November, 2020

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

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Denmark: High Court makes a decision against tax authority’s TP approach

16 October, 2020

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

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Denmark: National tax court clarifies TP documentation rules for intergroup companies

16 October, 2020

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

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Denmark: Tax Minister announces to exempt nonresident charitable organizations from WHT

25 September, 2020

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,

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Denmark: Government presents draft Budget for the year 2021

10 September, 2020

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

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Denmark: Ministry of Taxation publishes a Bill regarding deduction for R&D expenses

31 August, 2020

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.

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DAC6 Updates: Optional deferral of DAC6 reporting deadlines

30 July, 2020

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

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Denmark: Tax authority extends the initial DAC6 reporting by six months

06 July, 2020

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

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Denmark: Supreme Court makes a decision regarding royalties and TP documentation

30 June, 2020

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

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Denmark: Government proposes to extend the payment deadline of wage tax and VAT

08 June, 2020

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

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Denmark: Tax authority publishes a guide regarding DAC6

07 May, 2020

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

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Denmark: President announces to postpone a Bill for amending CFC rules

26 April, 2020

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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Denmark: Ministry of Taxation extends all filing deadlines, including transfer pricing documentation

12 April, 2020

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

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Denmark: Government announces a package of tax measures due to COVID-19 impact

23 March, 2020

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

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Denmark: Reminder for transfer pricing documentation submission due date

23 March, 2020

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,

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