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.
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.
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.
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).
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.
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 | 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
© 2017 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.