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Denmark: Consultation on draft legislation to implement Pillar Two side-by-side package, tax hybrid financing arrangements

Proposed amendments in line with recent OECD agreements

November 3, 2026

The Danish tax authority on October 2, 2026, published a consultation on draft legislation amending the Minimum Taxation Act, Corporate Tax Act, Tax Assessment Act, and various other laws in line with recent OECD agreements.

In particular, the draft legislation would implement the Pillar Two side-by-side package, subject hybrid financing arrangements to tax, and change the list of countries subject to defensive measures.

The consultation closed on October 30, 2026.


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

Lars Terkilsen | lars.terkilsen@kpmg.com

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