The Danish Parliament is considering draft Bill L 49, which was submitted on 6 November 2019 and provides for the implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reportable cross-border tax planning arrangements. This includes measures to require the reporting of cross-border tax planning arrangements and the exchange of information reported with other EU Member States. The reporting requirement primarily applies to intermediaries that design, market, organize, or manage the implementation of a reportable arrangement, but may also apply to taxpayers in certain cases, such as when the intermediary is subject to confidentiality obligations or where a taxpayer has designed an arrangement without external intermediaries.
As required by the Directive, the reporting requirements will apply from 1 July 2020, with initial disclosures required by 31 August 2020 in respect of reportable arrangements during the period 25 June 2018 to 30 June 2020. For reportable arrangements from 1 July 2020, reportable arrangements must be disclosed within 30 days.
The Parliament is also considering draft Bill L 48, submitted the same date, which provides for the amendment of existing controlled foreign company (CFC) rules to comply with the EU Anti-Tax Avoidance Directive (ATAD) as well as certain other measures (previous coverage).
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