Denmark: Updated guidance on transfer pricing documentation
Updated guidance regarding amendments to the transfer pricing rules
Updated guidance regarding amendments to the transfer pricing rules
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 guidance (Danish) (31 January 2022) allows taxpayers to submit the prior year’s Master file as a preliminary Master file when the Master file for the current fiscal year is not final by the submission deadline and the prior year’s Master file is less than one year old. In this situation, the taxpayer is required to briefly describe any significant changes concerning taxpayers that are not covered in the Local file.
The new transfer pricing documentation requirements apply for fiscal years beginning on or after 1 January 2021.
Background
Legislation enacted in November 2021 supplemented and updated the transfer pricing documentation rules to include a mandatory filing requirement for transfer pricing documentation required for 2021. It is these rules that provide that the transfer pricing documentation must be submitted to the Danish tax agency within 60 days of the due date for filing the tax return. Read TaxNewsFlash
The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.