Denmark: Parliament passes pillar two global minimum tax law

On 7 December 2023, the Danish Parliament passed legislation to implement the Pillar 2 global minimum tax (GloBE) rules. This legislation closely adheres to the framework established by the Council Directive (EU) 2022/2523 of 14 December 2022. On 23 June 2023, the Danish Ministry of Taxation introduced a draft bill for public review, with the objective of incorporating the EU minimum tax directive.

Key features of the Act:

  • Minimum Tax Rate: The Act imposes a global minimum tax rate of 15% on covered groups with annual consolidated revenue exceeding EUR 750 million in at least two of the previous four fiscal years.
  • Income Inclusion Rule (IIR) and Undertaxed Payment Rule (UTPR): The Act implements both the IIR and UTPR to ensure the minimum tax is achieved.
    1. The IIR applies to financial years commencing on or after 31 December 2023.
    2. The UTPR applies to financial years commencing on or after 31 December 2024, with specific exceptions.
  • Temporary Safe Harbor: Taxpayers have the option to apply a temporary safe harbor based on country-by-country reporting.
  • Qualified Domestic Minimum Top-Up Tax: The Act introduces a qualified domestic minimum top-up tax to ensure that Danish group members are effectively taxed at a rate of at least 15%.

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