Denmark's Ministry of Taxation is currently consulting on a draft bill that provides for the amendment of existing controlled foreign company (CFC) rules to comply with the EU Anti-Tax Avoidance Directive (ATAD) as well as certain other measures. The CFC amendments include a reduction in the CFC (passive) income test from half of total income to 1/3 of total income and the removal of the CFC financial asset test (greater than 10% of total assets). The amendments also include adjustments to the types of income considered CFC income, which is expanded to include other income generated from intangible assets, including...