Transfer Pricing Dokumentation (TP Documentation)
Transfer pricing documentation required for Danish companies with controlled transactions (related-party transactions) exceeding DKK 5m annually. Documentation must exist at the time of filing the corporate tax return and be provided to SKAT within 60 days of request.
Who this applies to
- Danish companies with related-party transactions exceeding DKK 5m in the income year
- Companies with cross-border controlled transactions
- Danish companies that are part of a group with consolidated revenue above DKK 5.6bn (country-by-country reporting requirement)
What to file
TP dokumentation filed with SKAT on request (not proactively submitted). Country-by-country (CbCR) reports for large groups filed annually via TastSelv Erhverv. A transfer pricing declaration is included in the corporate tax return for companies above the DKK 5m threshold.
How to file
TP documentation is maintained internally and submitted to SKAT electronically within 60 days of an audit request. CbCR is filed via TastSelv Erhverv within 12 months of the end of the accounting year. OECD guidelines (the arm's length principle, comparability analysis, method selection) form the basis for Danish TP rules.
Payment due
No direct payment — TP documentation is a compliance obligation. Transfer pricing adjustments identified by SKAT in an audit may result in additional corporate tax plus interest.
Penalties for missing this deadline
Fine for failing to provide TP documentation within 60 days: up to DKK 250,000 per year of non-compliance. SKAT can impose discretionary income adjustments without documentation. CbCR non-filing: fine per day. Intentional TP manipulation: criminal liability possible.
Filing checklist
- Identify all controlled transactions: sales, purchases, services, loans, IP licences between the Danish company and related parties
- Confirm whether total controlled transactions exceed DKK 5m — if so, TP documentation is mandatory
- Prepare master file (overordnet dokumentation): group overview, value chain, intangibles, financing, financial position
- Prepare local file (specifikationsoplysninger): transaction-level analysis, comparables, selected TP method, pricing justification
- Ensure documentation is completed by the corporate tax return filing deadline
- Review annually and update as transaction volumes or structures change
Documents you'll need
- Intercompany agreements for all significant controlled transaction types
- Benchmarking analysis or comparables database search (Bureau van Dijk, SKAT database)
- Transfer pricing method selection memo (CUP, TNMM, cost-plus, resale price, profit split)
- Functional analysis: functions performed, risks assumed, assets employed by each entity
- Financial analysis showing the actual arm's length outcome
Common mistakes to avoid
- Creating TP documentation retrospectively after SKAT requests it — contemporaneous documentation is required (must exist at filing, not created on demand)
- Not recognising that loans between related entities require TP documentation on interest rates
- Underestimating controlled transactions that together exceed DKK 5m — many small transactions that collectively exceed the threshold still require documentation
- Failing to update documentation annually when economic circumstances or transaction volumes change significantly
Never miss a Denmark deadline
AccountsOS tracks every Skattestyrelsen (Danish Tax Agency) and Erhvervsstyrelsen (Danish Business Authority) / CVR deadline and reminds you weeks ahead.
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