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GloBE Country Guide: Denmark

Summary

Status Enacted Law
LawOn February 3, 2025, the Danish Ministry of Finance issued draft legislation (Bill 2024-4606) for consultation. This is to amend the Danish Minimum Tax Act for the June 2024 and January 2025 OECD Administrative Guidance.

On December 18, 2024, the Danish Ministry of Taxation opened a public consultation on a draft Executive Order on the registration requirements.

On June 11, 2024, Law No. 684 was published in the Danish Official Gazette. This implements additional aspects of the OECD Administrative Guidance.

Law No. 1535 of December 12, 2023
Effective DateAccounting periods beginning on or after December 31, 2023
IIRYes (2024)
UTPRYes (2025)
QDMTTYes (2024)
Filing DeadlinesStandard
Safe HarboursYes, Transitional CbCR Safe Harbour + QDMTT Safe Harbour + Transitional UTPR Safe Harbour. The June 2024 Amending Law includes the NMCE Simplified Calculations Safe Harbour

Contents
  1. Legislation
  2. General
  3. Differences to Model Rules
  4. Qualifying Domestic Minimum Top-Up Tax
  5. Administration and Filing
  6. Penalties

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Legislation