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
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