Key takeaways
- 15% minimum tax: Applies to multinational and large Danish groups earning over €750M.
- OECD/EU aligned: Follows OECD Pillar Two and EU Directive 2022/2523.
- New rules: Introduces IIR, UTPR, and QDMTT; excludes the Faroe Islands and Greenland.
The Folketinget, Denmark's national legislature, has moved forward on a bill to implement a global minimum tax rate for Danish corporations part of multinational and large domestic enterprises. This initiative is in line with the OECD's Pillar Two strategy and the European Union's Directive 2022/2523. The bill's main feature is the establishment of a 15% minimum global tax rate for qualifying groups that have yearly earnings over 750 million euros in at least two of the past four fiscal years.
The bill also details the implementation of the income inclusion rule (IIR) and the undertaxed profits rule (UTPR) for designated financial years and introduces an additional tax called the qualified domestic additional tax (QDMTT). The new legislation excludes the Faroe Islands and Greenland.
Frequently asked questions
What is Denmark’s new global minimum tax?
Denmark will introduce a 15% minimum global tax rate for multinational and large domestic groups earning over €750 million in at least two of the past four years.
How will the new rules be applied?
The bill includes the Income Inclusion Rule (IIR), Undertaxed Profits Rule (UTPR), and a Qualified Domestic Minimum Top-up Tax (QDMTT), applying only to Denmark—not the Faroe Islands or Greenland.
