On 3 June 2021, the Danish Parliament passed Bill No L 89 on controlled foreign company (CFC) taxation. The law implements the CFC rules of the European Union’s (EU) Anti-tax Avoidance directive (Council directives (EU) 2016/1164 and (EU) 2017/952) (the ATAD) into Danish law.
The ATAD provides Member States with two options for CFC taxation:
- Model A: CFC taxation of non-distributed financial income
- Model B: CFC taxation of non-distributed income resulting from non-genuine arrangements put in place …