On 31 January 2022, 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 new guidance, states that, if the master file for the relevant year is not yet ready by the deadline for submission, the master file for the prior income year can be submitted as a temporary document if the following requirements are met:
• The provisional master file submitted is less than one year old at the submission deadline;
• It must be stated when the final Master File will be submitted for the relevant income year; and
• Significant changes affecting the Danish taxpayer for the income year in question that has not already been disclosed in the local file must be briefly described.
If these three conditions are met, the taxpayer is not obliged to apply for an extension of the filing deadline. The new transfer pricing documentation requirements apply for fiscal years beginning on or after 1 January 2021.
