The Tax Council was able to confirm that there was no permanent establishment in Denmark, as the gas storage did not meet all the conditions in Article 5 of the double taxation agreement, since after a specific assessment of the available information, the Tax Agency’s assessment was that the company in Denmark had the character of being of a preparatory nature or auxiliary species. The questioner’s business in Denmark consisted solely of temporary storage of its own gas until it was resold.
Source skat.dk
