Denmark country-by-country reporting in 2016 - KPMG Global
Share with your friends

Denmark: Country-by-country reporting for 2016

Country-by-country reporting in Denmark

The Danish Parliament has passed legislation that adopts country-by-country reporting. The new reporting requirements are expected to be implemented by means of a change to the Danish executive order concerning documentation relating to the pricing of controlled transactions, with effect from 1 January 2016.


Related content


The Danish government in September 2015 proposed legislation to provide measures that would enhance the Danish transfer pricing documentation requirements and include country-by-country (CbC) reporting. Read TaxNewsFlash-Transfer Pricing

CbC legislation

The Danish Parliament on 18 December 2015 passed the legislation to require CbC reporting. Accordingly, multinational groups whose ultimate parent company is a resident in Denmark will be required to make CbC reporting submissions. 

The CbC reporting rules will also affect foreign group entities that are residents in Denmark if certain conditions are met.

OECD standards, generally followed

The new Danish rules are generally in line with the CbC reporting plan as published by the OECD in October 2015. 

The structure and requirements of the new documentation standards are also similar to current transfer pricing requirements in Denmark, but with additional requirements with respect to tax agreements, intangible assets, and financing under the CbC rules.

The new CbC rules are based on the OECD's three-step approach requiring: (1) a master file, (2) a local file, and (3) a CbC report. The CbC report is to be submitted no later than 12 months after the end of the income year. The new rules will apply for income years beginning 1 January 2016 and later.

CbC reporting rules

For CbC reporting purposes, all Danish multinational groups with a consolidated turnover of at least DKK 5.6 billion (approximately U.S. $839 million) will be required to file a CbC report. The CbC report will then be made available to all countries where the group operates (i.e., through its subsidiaries and/or permanent establishments).

When the ultimate parent company of the group is a tax resident in Denmark, the CbC report will have to be submitted to the Danish tax authorities (SKAT).

Other subsidiaries in Denmark or foreign-based groups will have to submit the CbC report if certain conditions are met. These conditions would apply when:

  • The ultimate parent company is not required to file a CbC report in the jurisdiction where it is “fiscally resident” or
  • The ultimate parent company is a resident in a jurisdiction that has an agreement for the exchange of information with Denmark, but has not yet signed a specific agreement for the automatic exchange of CbC reports with Denmark, or
  • There are other measures preventing the automatic exchange of information.

KPMG observation

Entities that form part of a group and that are subject to the Danish documentation requirements need to consider steps to prepare their documentation structure so as to comply with the additional content requirements. Groups whose ultimate parent company is a resident in Denmark and have a turnover exceeding DKK 5.6 billion need to be ready to file CbC reports. 

According to information provided by SKAT to the Minister of Taxation, the number of Danish groups required to submit CbC reports is expected to range between 50 to 75 entities.


For more information, contact a tax professional with KPMG’s Global Transfer Pricing Services group in Denmark, with the KPMG member firm in Denmark, KPMG Acor Tax: 

Simon K. Schaadt | +45 5374 7044 | 

Martin Nielsen | +45 5374 7055 | 

Henrik Lund | +45 5374 7066 |

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?


Request for proposal