Denmark: Publishes new guidelines on TP documentation

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The Minister of Taxation issued order BEK no. 401 and 402 regarding transfer pricing documentation. The new documentation guidelines BEK no. 402 will replace the previous guidelines of BEK no. 42. The new guidelines include more specific documentation requirements than under the previous documentation guidelines. The new documentation guidelines are applicable from 1 January 2017.

The documentation requirements:

  • According to to the new rules, taxpayers must use the prices and terms of business with related persons comparable to those used in independent transactions and depending on their size when calculating taxes or income.
  • Taxpayers also need to prepare themselves and keep written records of the prices and conditions for the controlled transactions.
  • The documentation contains following two parts: (i) Master file documentation on the entire group and (ii) country-specific documentation for each taxpayer in the group.
  • Language: The documentation can be prepared in Danish, Norwegian, Swedish or English.
  • Timing: The requested documents must be sent to the Danish tax authority (SKAT) within 60 days.

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