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PE Watch | Latest developments and trends, March 2025

|Tax Alerts, Legislation & Policy, Le ...|United States, Denmark, India
United States, Denmark, India

PE tax rulings

Denmark rules on the existence of a PE for inventory maintenance

On 6 March 2025, the Danish Tax Council assessed in ruling SKM2025.124.SR whether a Swiss company had established a permanent establishment (PE) in Denmark under the Denmark-Switzerland tax treaty. The Swiss company was engaged in centralized procurement and the supply of fuel and related additives to sales companies operating service stations and convenience stores in Denmark. It owned inventory in Denmark under certa…