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Denmark: Expanded scope of CbC reporting under DAC9; amendments to Pillar Two rules

Pillar Two amendments related to joint taxation, deferred tax, and securitization entities

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december 19, 2025

Denmark amended its country-by-country (CbC) reporting rules to expand the information required for multinational enterprise (MNE) groups under EU DAC9. Table 2 in Annex III must now include detailed identifiers for each constituent entity, including full name, tax jurisdiction, registration numbers (CVR/SE), and foreign tax identification numbers.

In addition, amendments to the Minimum Taxation Act to align with OECD Pillar Two administrative guidance were enacted on July 1, 2025. The changes clarify rules on international joint taxation, deferred tax liabilities, and introduce provisions for securitization entities.
 

For more information, contact a KPMG tax professional in Denmark:

Sigita Pejanovic | sigita.pejanovic@kpmg.com

Christian Hjort | christian.hjort@kpmg.com

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