Share with your friends

Denmark: Proposals for changes to transfer pricing documentation rules

Denmark: Changes, transfer pricing documentation rules

The Danish Ministry of Taxation has proposed changes to the current transfer pricing documentation requirements.


Related content


Under the current transfer pricing rules, companies must prepare transfer pricing documentation contemporaneously. Also, the transfer pricing documentation must be ready no later than at the time for submission of the tax return. This means that the deadline for preparing the FY 2019 transfer pricing documentation for most companies is 30 June 2020—less than 100 business days from today. For companies with a financial year that does not follow the calendar year, other deadlines apply.

Under the current transfer pricing documentation rules, once requested by the tax authorities, the taxpayer must submit the contemporaneously prepared transfer pricing documentation within 60 days of the request. The Ministry of Taxation, however, has proposed changes to the rules so that if adopted, companies would be required to file their transfer pricing documentation.

Proposals for changes to transfer pricing documentation rules

Changes are proposed to the current documentation requirements— including two notable transfer pricing rule changes.

If the proposals are finalized, companies would be required to file the statutory transfer pricing documentation shortly after the tax return is filed (no exemptions seem to apply). Moreover, the legal basis for discretionary assessments would be formally tightened, significantly, in favor of the tax authorities.

If finalized, the submission requirement would apply for income years starting 1 January 2020 or later (i.e., the first submission under the new rules would be in August 2021 with the submission of transfer pricing documentation for FY 2020).

Read a March 2020 report prepared by the KPMG member firm in Denmark

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Want to do business with KPMG?


loading image Request for proposal