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 | email@example.com
Martin Nielsen | +45 5374 7055 | firstname.lastname@example.org
Henrik Lund | +45 5374 7066 | email@example.com
Johnny Bøgebjerg | +45 5374 7090 | firstname.lastname@example.org
© 2018 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.