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 parties does not trigger CFC taxation if the underlying intellectual property (IP) to a significant …