Denmark: Danish Assessment Board issues ruling on profit allocation to permanent establishment
The Danish Assessment Board gave its ruling on 16 August 2016, in the case of SKM2016.353.SR on the correct profit allocation to a permanent establishment (PE) in the form of a construction company. Facts of the case: The taxpayer is a foreign
See MoreDenmark: Publishes new transfer pricing documentation guidelines
The Danish Ministry of Taxation issued two Orders : BEK nos. 401 and 402, on 28 April 2016, concerning transfer pricing documentation. The new documentation guidelines BEK no. 402, which will replace the previous guidelines of 24 January 2006 (BEK
See MoreIMF report comments on the economic policy of Denmark
On 4 May 2016 the IMF issued a report on the economy of Denmark following the conclusion of consultations under Article IV of the IMF’s articles of agreement. Denmark scores well in international comparisons of business competitiveness and the
See MoreDenmark: Plans for the introduction of alternative dispute resolution for TP cases
The Minister of Taxation announced on 2 May 2016, for transfer pricing cases they are planning for the introduction of alternative dispute resolution (ADR) system. The introduction of ADR is considered essential in order to assurance that transfer
See MoreDenmark proposes amendments for the several laws
The Ministry of Taxation submitted a law proposal (L 123) to the parliament on 23 February 2016, amending several laws. The proposal includes the following amendments: Participation exemption: -The rules on the participation exemption are enhanced
See MoreDenmark: IMF report on the value added tax gap
On 23 February 2016 the IMF published a technical assistance report on the analysis of the value added tax (VAT) gap in Denmark. Estimates of the VAT gap in Denmark were made for the years 2008 to 2012. The IMF’s methodology for the Revenue
See MoreDenmark: Government Passes bill on Country-by-Country Reporting
On 18 December 2015 the Danish Parliament approved the draft Bill introducing Country-by-Country Reporting based on Action 13 of the Organization for Economic Co-operation and Development (OECD) project on Base Erosion and Profit Shifting
See MoreDenmark publishes a draft bill to relax the taxation of outbound and inbound dividends
The Danish Minister of Taxation published a draft bill on 5 October 2015. This draft bill planned to relax the taxation of certain categories of outbound and inbound dividends in order to comply with European Union (EU) law. However, the proposals
See MoreDenmark: Government publishes a proposal to introduce CbC reporting
The Danish government published a proposal on 18 September 2015 to amend the current tax law, and provide measures that would increase the Danish transfer pricing documentation requirements and include country-by-country (CbC) reporting. The
See MoreDenmark: Budget for 2016
The Budget for 2016 was presented to the parliament on 6 October 2015. The following main changes are proposed in the Budget: Corporate taxation: Country-by-country reporting for income and taxes paid is introduced for multinational enterprises.
See MoreDenmark publishes information on the Budget for 2016
The Danish government published information on the Budget for 2016 on 29 September 2015. The tax measures set out in the Budget, which will be presented to the parliament on 8 October 2015, include some important changes as summarized below: -
See MoreGhana: Treaty with Denmark boost Denmark’s investment in Ghana
Statistics from the Ghana Investment Promotion Centre (GIPC) reveal that direct investment from Denmark to Ghana in early 2014 amounted to over US$57.6million. The Finance Committee Report of Parliament also indicated that imports from Denmark to
See MoreDenmark: National Tax Tribunal Decision on foreign exchange losses on sale of shares
The Customs and Tax Administration published National Tax Tribunal Case No. 122-0208149 on 30 June 2015. The Tribunal held that foreign exchange losses realized on the sale of shares of a subsidiary resident in another Member State are not
See MoreDenmark: Parliament Enacts Law to Combat Tax Evasion
The Danish parliament has adopted a law proposal (L 167) that includes some of the measures agreed on in the package of proposals to combat tax evasion. The law covers the following measures: The control of foreign trusts is improved in order
See MoreDenmark: Minister of Taxation Clarifies Danish Treaty Policy
The Ministry of Taxation published a press release summarizing the statements given by the Minister to Parliament on 29 April 2015 in an open hearing regarding the Danish treaty policy. The main emphasis of the hearing was the conclusion of tax
See MoreDenmark: Information Published on Transfer Pricing cases
The Ministry of Taxation published on 11 March 2015 information regarding the transfer pricing (TP) adjustments made in 2014 and the main transfer pricing focus areas for 2015. During 2014, the tax authorities dealt with 76 transfer pricing cases,
See MoreDenmark: Filing a paper form is no longer possible for companies
The Ministry of Taxation announced, on 3 February 2015, a new schedule relating to the digitalization of corporate tax filing. A new schedule was required as the necessary adjustments to the IT systems will be more time-consuming and complicated
See MoreDenmark & Ghana DTA ratified by Denmark
The Danish government ratified the Denmark-Ghana Double Tax Treaty (DTA) on 19 December 2014, which was signed on March 24, 2014. Further details of the treaty will be reported
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