As a general rule, the Danish CFC rules apply in all cases, i.e. with no exemptions based on whether the CFC is undertaking substantial.
However, "other income generated from intellectual property" (eg. embedded royalties) is not included as CFC-income where the controlled foreign company carries on a substantive economic activity supported by staff, equipment, assets and premises, as evidenced by relevant facts and circumstances and the "other income generated from intellectual property" is derived from those substantial activities.
It is a condition, that the parent company submits evidence of the substantial activities of the CFC.