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On 7 May 2019, the Danish Tax Agency published its binding ruling regarding the tax residence and permanent establishment (PE) status of a UK company in Denmark in relation to a home office used by its Danish General Manager. 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 fixed place of business PE for the UK company.

Further information about the ruling is set out below.


The binding ruling concerns a UK based geological investigation company with the headquarters, office facilities and operations in London. The company has established subsidiaries and obtained licenses in the locations where it has geological investigation projects. The local subsidiaries own the intangibles associated with the geographical location and the project.

The CEO and the board of the UK company (except for one member) are based in London. Administrative functions, daily operations and the majority of the technical work are performed by employees in London.