The report should be submitted electronically to the Danish Tax Agency (Skattestyrelsen) in a fixed XML file format according to the OECD guidelines.

Please see the CbC reporting guide of the Danish Tax Agency (please note that this guide is in Danish) and the guide on XML file format (oecd.org) which is also a user guide to businesses subject to Country-by-Country reporting.

How do you submit the report?

Please submit the report by logging on to E-tax for businesses (TastSelv Erhverv) -> 'Skat' (Tax) -> 'Land for land' (CbC) (Country-by-Country (CbC))

Please see Notification of CbC Reporting below for information on submitting notification of CbC reporting.

New reporting form from 4 February 2021

The OECD has published a new reporting form for CbC reporting. This means that as from 4 February 2021, you need to use the new CbC 2.0 form when reporting. This also applies when you report for previous years and when you correct or delete previous reports.

There are a few new features you should be aware of when you use the new CbC 2.0 form. A ReportingPeriod element has been added under ReportingEntity where you must enter the start and finish date for the period. In addition, it is recommended that you also fill in some optional elements that have been added.

Read more about the new CbC 2.0 form in the OECD’s CbC 2.0 User Guide (oecd.org) or in our CbC reporting guide (in Danish).

According to section 3B(14) of the Danish Tax Control Act (Skattekontrolloven), Danish businesses that are part of a multinational enterprise (MNE) group with a consolidated group turnover equal to or exceeding DKK 5.6 bn. per income year must notify the Danish Tax Agency before the end of the current income year of which of the group enterprises will be obligated to submit a CbC Report for the following income year.

Please see the CBC notification guide of the Danish Tax Agency.

How do you submit the notification?

Please submit the notification of CbC Reporting by logging on to E-tax for businesses (TastSelv Erhverv) -> 'Skat' (Tax) -> 'Land for land' (CBC).

Only the management company has to submit a notification on behalf of the joint taxation group.

Please see our CbC reporting guide for technical assistance. (Please note that this guide is in Danish).

Please see our CBC notification guide for notification assistance.

Overview of guides by the OECD:

• See the OECD/G20's BEPS report on Transfer Pricing Documentation and Country-by-Country Reporting (oecd.org)
• See OECD's guidance on Country-by-Country Reporting (oecd.org)
  
• See signatories of the multilateral competent authority agreement (oecd.org)
• See Country-by-Country exchange relationships (oecd.org)
• See agreement with the United States of America on exchange of Country-by-Country Reports (skm.dk)
• See Council Directive 2016/881/EU (DAC4)
• See our legal guide on the Country-by-Country Reporting duty, section C.D.11.13.2 (Please note that this link is in Danish)
• See SKM2017.745.SKAT about notification and reporting to us (Please note that this link is in Danish)

The OECD/G20 standard on exchange of CbC reports is part of the OECD/G20’s Base Erosion and Profit Shifting (BEPS) project.

• Section 3B(10-16) of the Danish Tax Control Act Skattekontrollovens (retsinformation.dk) (Please note that this link is in Danish).
• Danish Act on implementation of Directive 2016/881/EU (DAC4) (Lov om implementering af direktiv 2016/881/EU (DAC4) (retsinformation.dk) (Please note that this link is in Danish)
• Danish Executive Order on Country-by-Country Reporting (Bekendtgørelse om land for land-rapportering) (retsinformation.dk) (Please note that this link is in Danish)