A high-level tax authority in Denmark has found that the Irish subsidiary of a multinational was liable to pay Danish corporation tax for its business in that country. In a new decision, the Skatterådet (Tax Council) has ruled that the presence of a warehouse storing products for distribution in Denmark, combined with that of group employees in the country, constituted a permanent establishment subject to Danish taxation. The multinational had requested an advance tax ruling, claiming that its Irish unit did not have a permanent establishment in Denmark, and the Skatterådet has published a redacted version of its response without…

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