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Danish Ruling that Subcontracted Activities may Constitute PE

|Treaty Development|Denmark-Austria
Denmark-Austria

On 23 August 2017, the Danish tax authority (SKAT) published a binding ruling on the existence of a permanent establishment (PE) in Denmark of a foreign company planning to subcontract certain activities in Denmark. The ruling involves an Austrian company that constructed a building in Denmark that was completed in 2016. In order to maintain the facades of the building, the Austrian company intends to enter into a 10-year agreement with another foreign company to manage maintenance, cleaning…

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