Denmark Tax Agency Clarifies PE Rules for Employee Home Offices Under DTA With Germany

Oct. 22, 2021, 5:00 AM

The Danish Customs and Tax Administration Oct. 18 posted online Tax Council Decision No. SKM2021.539.SR, explaining permanent establishment (PE) rules for employee home offices under the 1995 DTA with Germany. A German company operating as a manufacturer, marketer, and distributor of chemical products employed a Danish taxpayer who lived in Denmark and did most of his work from his Danish home office as a global regulatory manager. The company requested clarification as to the PE status of the employee’s Danish home office. The tax agency held that the employee’s home office doesn’t qualify as a PE for the company because: ...

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