PE rulings
CEO working from home in Denmark creates a PE
On 2 September 2024, the Danish Tax Board issued binding ruling SKM2024.432.SR, concluding that a Swedish company had established a permanent establishment (PE) in Denmark due to its Chief Executive Officer's (CEO) working partially from home in Denmark.
The CEO, a Danish resident, works from a home office in Denmark 40% of the time, with the remaining 60% spent at the company's offices in Sweden. While the company's overall management remain…