Danish Parliament Considering Bill to Ensure Minimum Taxation Act Meets OECD Model Rules and Guidelines for Pillar 2 Global Minimum Tax and Amend Non-Cooperative List

The Danish parliament is considering draft bill L 186, which introduces amendments to ensure that the Minimum Taxation Act fully meets the OECD's model rules and the OECD's administrative guidelines. In particular, safeguard rules are proposed to prevent groups from entering into circumvention arrangements with a view to utilizing the special transitional rule in the Minimum Taxation Act on the possibility of setting the surcharge at zero on the basis of the group's country-by-country report…