Transfer pricing documentation is a central requirement for multinational companies in Denmark to ensure that intra-group transactions are conducted at arm’s length.
This year, there is particular reason to pay attention, as a series of new rules will apply for the income year 2025, affecting both thresholds and documentation obligations.
Get started with your documentation work now, so you meet the deadline at the end of August.
Why Transfer Pricing?
All multinational companies exceeding the Danish thresholds must prepare and submit both a master file and a local file, describing global activities and local intra-group transactions.
The rules for transfer pricing are designed to ensure that intra-group transactions are conducted at arm’s length. This means that prices and other terms for controlled transactions must correspond to what independent parties would have agreed upon.
Be Aware of New Rules
The rules for transfer pricing documentation have changed for the income year 2025. In summary, this means:
- Fewer companies will need to prepare full transfer pricing documentation
- Some transactions no longer need to be described in the documentation
Benefits of Acting Now
- Avoid fines for incomplete or late documentation submission
- Reduce the risk of tax audits
- Optimize the group’s transfer pricing setup and gain an overview of transactions
If you do not meet the submission deadline at the end of August, it may result in significant fines, increased scrutiny from the Danish Tax Agency, and discretionary income assessments.
How Grant Thornton Can Help
Grant Thornton’s transfer pricing specialists assist companies with, among other things, preparing transfer pricing documentation. The team can help you:
- Assess your company’s current documentation and identify any gaps
- Prepare both master and local files in accordance with Danish requirements
- Submit documentation and appendices to the Danish Tax Agency within the deadline
Need Advice?
The deadline is approaching fast, so we recommend that you start the transfer pricing process now.
If you have questions or need assistance, you are welcome to contact Grant Thornton’s transfer pricing specialists below.
