OrbitaxDanish Tax Authority Holds Storage Facility and Employees May Constitute Permanent Establishment Under Treaty with Ireland and MLI Anti-Fragmentation Rule
|Treaty Development|Denmark-Ireland
The Danish Tax Administration recently published a binding answer from the Tax Council regarding the permanent establishment implications for an Irish company (H1). H1 belongs to a group, the H Group, which is the market leader for certain products (X products) and has a significant presence in several countries.
In Denmark, the H Group has acquired a number of businesses owned and operated …
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