Denmark: Public consultation on draft bill to implement Pillar Two global minimum tax
Taxpayers have until 18 August 2023 to provide comments to the consultation process.
Taxpayers have until 18 August 2023 to provide comments to the consultation process.
The Danish Ministry of Taxation on 23 June 2023, launched a draft bill (Danish) for public consultation to implement the EU minimum tax directive.
The directive is based on the OECD’s Pillar Two Model Rules, and the steps toward implementation are aligned with the directive’s requirements to implement the rules by 31 December 2023.
The wording and construction of the draft bill is very close to the directive, meaning that for calendar-year taxpayers the rules will have an effect as of 1 January 2024 through the so-called “income inclusion rule” (IIR), with the “under-taxed profits rule” (UTPR) to come into effect one year later. In addition, the bill also includes a “domestic minimum top-up tax” (DMTT) with effect from 1 January 2024. On certain specific points, the treatment under the minimum tax rules is still unclear, which have to be clarified both within Danish law and the OECD in the coming months.
Taxpayers have until 18 August 2023 to provide comments to the consultation process.
Read a June 2023 report prepared by the KPMG member firm in Denmark
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