Denmark has published Law No. 1180 of 8 June 2021 in the Official Gazette, which provides for the amendment of existing controlled foreign company (CFC) rules to comply with the EU Anti-Tax Avoidance Directive (ATAD). As previously reported, this includes:
- The expansion of the control test to include where a taxpayer itself or together with associated persons directly or indirectly owns at least 50% of the voting rights, capital, or rights to profit in the CFC, with a 25% ownership threshol…