Under the Danish CFC legislation, a Danish resident parent company is liable to taxation of the income (or only the CFC income) of an entity which is not subject to tax in Denmark, if: 

(1) The Danish parent company by itself, or together with its associated enterprises holds a direct or indirect participation of more than 50 percent of the voting rights, or owns directly or indirectly more than 50 percent of capital or is entitled to receive more than 50 percent of the profits of that entity;

 (2) More than 33% of the subsidiary's taxable income derives from CFC-income. The rules applies similarly to foreign permanent establishments.