May 2022, the Danish Tax Council issued a decision on Danish domestic rules reflecting the agency PE clause under article 5(5) of the OECD Model (2017). This article examines the facts of the case and the reasoning of the Tax Council.
May 2022, the Danish Tax Council issued a decision on Danish domestic rules reflecting the agency PE clause under article 5(5) of the OECD Model (2017). This article examines the facts of the case and the reasoning of the Tax Council.