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Denmark passes Pillar Two

07 December 2023

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Tax Alerts, Information Reporting, Legis...

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Denmark

On 7 December 2023, the Danish Parliament passed Bill No. L 5 implementing Pillar Two into Danish law.The global minimum tax rules are incorporated into a new law, the Minimum Taxation Act (Minimumsbeskatningsloven). The law closely follows the structure of Council Directive (EU) 2022/2523 of 14 December 2022 and includes clarifications and interpretations published by the OECD in 2022 and 2023. Among other things, taxpayers can elect to apply a temporary safe harbor based on country-by-country reporting. The law also introduces a qualified domestic minimum top-up tax.The Income Inclusion Rule (IIR) is applicable for financial years beginning on 31 December...