Denmark International & Cross-Border Guides
6 guides on Tax treaties, non-residents, US citizens, and Nordic rules.
Denmark Cross-Border M&A Tax Guide (Fusion, Spaltning, Tilførsel af Aktiver)
Danish cross-border M&A tax — skattefri fusion/spaltning involving foreign companies, cross-border asset contributions, EU Merger Directive implementation (Fusionsskatteloven), exit taxation, loss carryforwards in cross-border restructurings, and hybrid mismatch rules.
Denmark Cross-Border Tax Guide (Non-Danish Income, Foreign Assets)
Danish cross-border tax — reporting non-Danish income, foreign assets, tax treaties, foreign tax credit, and double taxation relief.
Denmark Permanent Establishment Guide (PE Rules, Profit Attribution, Compliance)
Danish permanent establishment rules — PE definition under Danish domestic law (SEL §2) and tax treaties (Article 5 OECD MC), construction PE (30 days domestic vs 12 months treaty), agency PE, service PE, profit attribution under the Authorised OECD Approach (AOA), registration and compliance obligations, PE exit tax, and risk mitigation.
Denmark Tax Treaties Guide (Double Taxation Treaties, Treaty Relief, MAP)
Danish double taxation treaties — network of ~100 treaties, key provisions for business (dividends, interest, royalties WHT rates), treaty relief procedures, Mutual Agreement Procedure (MAP), Limitation on Benefits, MLI impact, and beneficial ownership requirements.
Denmark Transfer Pricing Guide — Arm's Length, Documentation, CbCR
Danish transfer pricing rules — arm's length principle, controlled transactions, documentation requirements (master file + local file), thresholds, deadlines, penalties, and Country-by-Country Reporting.
Denmark Tax Guide for US Citizens (FATCA, FBAR, PFIC, Treaty)
Danish tax rules for US citizens living in Denmark — US worldwide taxation, FATCA and FBAR reporting, US-DK tax treaty provisions, Foreign Tax Credit (FTC), PFIC rules for Danish investment funds, US retirement accounts (IRA, 401k) in Denmark, Danish PAL tax vs US tax, Social Security Totalisation Agreement, and practical compliance strategies.