Denmark Issues amendments to Pillar 2 Law and a GIR Regulation

On December 19, 2025, the Danish Official Gazette published an Executive Order providing for GIR information reporting requirements:

On December 17, 2025, the Danish Official Gazette published Law No. 1643 to amend the Minimum Tax Act.

Amendment Law

QDMTT – Stateless Entities

An amendment to Section 47(1) of the Minimum Tax Law now provides that the QDMTT applies to stateless entities when they are established under Danish law, and stateless permanent establishments that have activities in Denmark.

Under the OECD Administrative Guidance, a domestic minimum tax does not need to apply to Stateless Constituent Entities or permanent establishments to be a QDMTT. However, jurisdictions can impose a QDMTT on these entities when they are created under the domestic law of the jurisdiction (or where a permanent establishment has a place of business in the QDMTT jurisdiction).

An amended Section 53(1) of the Minimum Tax Law also applies the GIR filing requirement to Stateless entities. 

DAC9 Implementation

A number of amendments to Section 53 of the Minimum Tax Law also apply the DAC 9 GIR reporting and exchange requirements into domestic law. 

Payment

Payment of top-up tax is required by 17 months after the last day of the reporting year (increased to 20 months in the commencement year) under Section 69(1) of the Minimum Tax Law. The Amendment Law changes the wording of this to 2 months after the deadline for submitting the GIR.

Executive Order on Submission of GIRs and Notifications

The Executive Order provides for additional administrative details for the submission of the GIR and double filing relief notifications.  This ties into the OECD GIR and EU DAC9 guidance.