Executive summary

On 22 April 2021, the Danish Minster of Taxation proposed the following key changes to Bill No L 89 on controlled foreign corporation (CFC) taxation:

• A partial substance test regarding “other income from intangibles.” If the test is met, no CFC taxation will be triggered.
• Certain exemptions from CFC taxation included in the original draft law are abolished.
• Royalty income from third …