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The bill introduces defensive measures and sanctions against countries that do not live up to international tax standards and good tax practices. The Danish Ministry of Taxation submitted the new bill to public consultation on 12 November 2020.
The reintroduced draft of the proposed CFC bill still does not contain the exemption available in the ATAD Directive where CFC taxation is not applied if the CFC entity has a substantive economic activity (substance test).
Consequently, transfer pricing documentation must be submitted to the tax authorities along with the corporate income tax return in the future.
The Danish Government has reached a political agreement on a new pension reform, which is to be partly financed through an annual mark-to-market capital gains tax on certain real property assets.
Consequently, the Royalty payments between affiliated companies were deductible as operating expenses
The global health pandemic has plunged business and economies into crisis mode, upending the way we work and live. Companies must rethink their business models and be open to pivoting to help sustain operations. Every company will have to respond in their own way, but many of the questions will...
Consequently, the verdict of the High Court was repealed, meaning that the taxpayer was relieved of a 6-month suspended prison sentence and a fine of DKK 750,000