The Danish tax authorities (SKAT) today announced that country-by-country (CbC) notifications must be submitted electronically and in a standardized format on Form 05.034.
New Form 05.034 is available on the SKAT website and must be uploaded through SKAT's secure digital communication line (TastSelv Erhverv: Skatteforhold - selskaber og foreninger -> Tilkendegivelse vedr. CbC).
The notification is required for all Danish companies / foundations / associations and permanent establishments that form part of a group subject to prepare and submit the CbC report. For companies covered by Danish joint taxation, only the “administration company” is required to complete the CbC notification form and provide the form to SKAT. Taxpayers that have already submitted a CbC notification to SKAT and received a receipt are not required to re-file the notification on the new form.
For corporate groups required to file CbC reports, the timing of the notification requirement in Denmark is determined based on the local company’s fiscal year. Notification must be provided to SKAT no later than the end of the fiscal year for which the CbC report is submitted.
Information in the notification concerning the identity of the group company filing the CbC report must include certain information such as its full entity name, address, tax jurisdiction, and company number (the CVR number). If the filing company is a non-Danish resident, the information must include a tax identification number for the tax jurisdiction in question. SKAT must also be notified if there is a change in circumstances no longer requiring the submission of the CbC report.
Based on this new guidance, Danish and foreign groups in Denmark with a consolidated group turnover of more than DKK 5.6 billion (approximately €750 million) need to be aware of the requirement to notify the Danish tax authorities about the submission of the CbC report.
For more information, contact a tax professional with KPMG’s Global Transfer Pricing Services group in Denmark, with the KPMG member firm in Denmark, KPMG Acor Tax:
Simon K. Schaadt | +45 5374 7044 | firstname.lastname@example.org
Martin Nielsen | +45 5374 7055 | email@example.com
Henrik Lund | +45 5374 7066 | firstname.lastname@example.org
Johnny Bøgebjerg | +45 5374 7090 | email@example.com
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