Danish Parliament Approves Bill for ATAD-Compliant CFC Rules

On 3 June 2021, the Danish Parliament approved Bill L 89 in its third reading, which provides for the amendment of existing controlled foreign company (CFC) rules to comply with the EU Anti-Tax Avoidance Directive (ATAD). The main amendments include:

• 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 threshold for …