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Danish Ruling Holds Limited Supervisory Activities for Subcontracted Project Do Not Constitute PE

|Approved Changes|Denmark
Denmark

On 9 May 2017, the Danish tax authority (SKAT) published a binding ruling concerning the existence of a permanent establishment in Denmark as a result of supervisory activities for subcontracted construction work. The rulings was requested by Y BV, a company resident in country A that won a contract that included the construction of a special structures in Denmark (company name and country not provided). Since Y BV was unable to construct the special structure in Denmark itself, it subcontra…

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