Denmark Tax Agency Clarifies Danish Corporate Taxation of British Company Under 1980 DTA With U.K.

The Danish Customs and Tax Administration April 8 posted online Tax Council Binding Answer No. SKM2026.156.SR, clarifying the Danish corporate taxation of a British company under the 1980 DTA with the U.K. The taxpayer, a U.K.-registered company, was wholly owned and managed by an individual tax resident in Denmark, who made key decisions from a Danish home office while limited operations continued in the U.K. The taxpayer sought clarification on issues pertaining to tax liability, tax residence, and permanent establishment (PE) status. Upon review, the Tax Council found that: 1) the taxpayer was fully liable for Danish corporate tax because ...