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Denmark Publishes Law to Ensure Minimum Taxation Act Meets OECD Model Rules and Guidelines for Pillar 2 Global Minimum Tax and Amend Non-Cooperative List

25 June 2024

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Approved Changes

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Denmark

Denmark has published Law No. 684 of 11 June 2024 in the Official Gazette, which introduces amendments to ensure that the Minimum Taxation Act fully meets the OECD's model rules and administrative guidelines for the Pillar 2 global Minimum tax. In particular, safeguard rules are introduced to prevent groups from entering into circumvention arrangements with a view to utilizing the special transitional rule in the Minimum Taxation Act on the possibility of setting the surcharge at zero on the basis of the group's country-by-country reports. Simplified calculation rules are also established for the application of the permanent exemption (derogation) provision...