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20 December 2017

Danish Court rules PE created by construction activities effectively carried out through a fixed place in Denmark

In a binding ruling dated November 15, and published December 11, (SKM2017.710.ØLR), the Danish Eastern High Court ruled that an individually owned Polish construction company, which had been carrying out business through a Danish fixed place for several years, created a Danish permanent establishment (PE) per article 5(1) of the Danish-Polish double tax treaty (the Treaty).

A Global Tax Alert, attached below, provides additional details.

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ATTACHMENT

Full text of Tax Alert 2017-2163

Document ID: 2017-2163

 

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