Tag Archives: transfer pricing

Public consultation on simplifications of transfer pricing documentation

On 23 June the Danish ministry of Taxation opened a public consultation to simplify transfer pricing documentation. The current rules require transfer documentation for all intra-group transactions, also between purely domestic situations.

The government proposes that the obligation to document applies only in situations where there is an actual risk that tax avoidance and tax arbitration may occur. This means that the requirement will be relaxed for transaction between Danish companies in the same group that are both subject to Danish corporate income tax.

The details of the consultation can be found here https://hoeringsportalen.dk/Hearing/Details/65287 . The proposal is expected to enter into force on 1 January 2022.