No fixed establishment in Denmark for a gas storage, as the company is of a preparatory or auxiliary nature

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

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