The Danish government published a proposal on 18 September 2015 to amend the current tax law, and provide measures that would increase the Danish transfer pricing documentation requirements and include country-by-country (CbC) reporting. The proposal suggests that multinational groups, when the ultimate parent company is a resident in Denmark, would be required to make CbC reporting submissions.
The new reporting requirements would be implemented by means of a change of a Danish executive order concerning documentation relating to the pricing of controlled transactions.
Reporting requirements are:
- It is proposed that 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.
- The CbC report would then be made available in all countries where the group operates.
- If the ultimate parent company of the group were a tax resident in Denmark, the CbC report would have to be submitted to the Danish tax authorities.
Furthermore, it is proposed that other subsidiaries in Denmark or foreign-based groups would have to submit the CbC report if certain conditions are met.
