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Permanent Establishment - recent decision by Denmark
02 August 2019 Caroline Jones, Employment tax director
The Danish Tax Agency recently published its binding ruling regarding the tax residence and permanent establishment status of a UK company in Denmark, in relation to a home office used by its Danish General Manager. The company is based and headquartered in London. The ruling concluded that even though the UK company should not be considered a Danish tax resident, the General Manager’s home office in Denmark creates a permanent establishment for the UK company. The reasoning given for the decision was:
it is a place of business where regular work for the company is performed;
it is a fixed business location due to it being the General Manager’s primary work location; and
the company carried on its business there through the General Manager, who is considered to undertake a senior role making significant decisions and completing work that is not purely preparatory or auxiliary in nature.
This ruling could have an impact for UK universities where they have employees based in Denmark.
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02 August 2019 
Caroline Jones, Employment tax director
