Denmark: New executive order on country-by-country reporting

Denmark: New executive order on CbC reporting

A new executive order relevant for Danish and foreign groups in Denmark with a consolidated group turnover of more than approximately €750 million has been issued to provide detailed rules for country-by-country (CbC) reporting.

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Executive order

The Danish Parliament passed legislation to adopt CbC reporting in December 2015 (L 2015-12-29 no. 1884). Read TaxNewsFlash-Transfer Pricing

Subsequently, a Danish executive order No. 1133 (27 August 2016) was issued to provide detailed rules on notice requirements and on how the CbC report must be completed. The executive order was effective 1 September 2016.

Notification requirement

For corporate groups required to file CbC reports, notification must be provided in a digital form to the Danish tax authorities (SKAT) no later than the end of the income year for which the CbC report must be submitted.

  • If the ultimate parent company is a Danish company, the group company filing the CbC report must be identified in the notification.
  • If the ultimate parent company is not a Danish company, the notification to SKAT must include information on what group company is required to file the CbC report and in what tax jurisdiction the company in question is resident.

The information concerning the identity of the group company must include its “full” name, address, tax jurisdiction, and company number (CVR). Foreign companies must provide a tax identification number for the tax jurisdiction in question.

Going forward, SKAT must be notified if there is a change in circumstances no longer requiring the submission of the CbC report (in other words, the requirements for CbC reporting cease to exist).

CbC reporting requirement

With the new executive order, the Danish requirements have been aligned with the requirements and definitions set forth in Annex III to chapter V in OECD’s “Guidance on Transfer Pricing Documentation and Country-by-Country Reporting.” The submission of the CbC report must be made digitally, according to SKAT's instructions.

KPMG observation

Tax professionals in Denmark have observed that 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 | 

Martin Nielsen | +45 5374 7055 | 

Henrik Lund | +45 5374 7066 |

Johnny Bøgebjerg | +45 5374 7090 |

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