Denmark: Updated guidance on transfer pricing documentation

Updated guidance regarding amendments to the transfer pricing rules

Updated guidance regarding amendments to the transfer pricing rules

The Danish Ministry of Finance issued updated guidance regarding amendments to the transfer pricing rules requiring the submission of the transfer pricing documentation within 60 days of the due date for filing the tax return, unless an extension is granted.

The guidance (Danish) (31 January 2022) allows taxpayers to submit the prior year’s Master file as a preliminary Master file when the Master file for the current fiscal year is not final by the submission deadline and the prior year’s Master file is less than one year old. In this situation, the taxpayer is required to briefly describe any significant changes concerning taxpayers that are not covered in the Local file.

The new transfer pricing documentation requirements apply for fiscal years beginning on or after 1 January 2021.

Background

Legislation enacted in November 2021 supplemented and updated the transfer pricing documentation rules to include a mandatory filing requirement for transfer pricing documentation required for 2021. It is these rules that provide that the transfer pricing documentation must be submitted to the Danish tax agency within 60 days of the due date for filing the tax return. Read TaxNewsFlash

 

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