Denmark Tax Agency Seeks Comments on Draft Guidance for PEs, Management Seats Due to Coronavirus

The Danish Customs and Tax Administration June 5 opened a consultation on draft guidance for the tax treatment of permanent establshments (PEs) and management seat locations under DTAs due to the coronavirus pandemic. The draft guidance clarifies that: 1) employees working from home due to the pandemic don’t constitute a PE for their employer company; 2) temporary interruptions in construction because of lack of material or labor are considered in determining PE status; 3) a company’s management seat doesn’t change due to a temporary travel restrictions on management due to the pandemic; 4) general tax residency rules don’t apply for ...