- Tax Ruling Issued: On October 14, 2024, the Danish Tax Board ruled that installation work by a foreign entity creates a Permanent Establishment (PE) in Denmark.
- No Tax Treaty Implications: The foreign entity, with no office in Denmark and limited employee presence, was subject to PE rules due to the absence of a tax treaty with its home jurisdiction.
- Immediate PE Recognition: Under Danish Tax Law, installation activities are recognized as creating a PE from the first day of work, bypassing the usual 12-month threshold.
Source EY
