On 3 June 2021, the Danish Parliament passed Bill No L 89 on controlled foreign company (CFC) taxation. The law implements the CFC rules of the European Union’s (EU) Anti-tax Avoidance directive (Council directives (EU) 2016/1164 and (EU) 2017/952) (the ATAD) into Danish law.The ATAD provides Member States with two options for CFC taxation:Model A: CFC taxation of non-distributed financial incomeModel B: CFC taxation of non-distributed income resulting from non-genuine arrangements put in place for the essential purpose of obtaining a tax advantageExisting Danish CFC taxation is based on model A and CFC taxation requires that more than 50% of...