PE tax rulings
Denmark rules on the existence of a PE for inventory maintenance
On 6 March 2025, the Danish Tax Council assessed in ruling SKM2025.124.SR whether a Swiss company had established a permanent establishment (PE) in Denmark under the Denmark-Switzerland tax treaty. The Swiss company was engaged in centralized procurement and the supply of fuel and related additives to sales companies operating service stations and convenience stores in Denmark. It owned inventory in Denmark under certa…