Transfer Pricing

Transfer pricing is one of the tax areas where there have been several legislative changes in recent years, both nationally and internationally. Groups must therefore adapt to the new rules and comply with disclosure obligations, etc.

The groups are faced with increased documentation requirements or fines if national and international legislation is not complied with. Danish legislation requires that the group's controlled transactions are carried out by the arm's length principle, which must be documented to the authorities.

In Denmark, it is mandatory to submit transfer pricing documentation to the authorities if you are covered by the extended documentation requirements.

Extended documentation requirements apply to groups that either have:

• +250 full-time employees
• +250 million in revenue and + 125 million in total assets

Both are measured at a consolidated level.

In addition, you may be subject to limited documentation requirements if you have controlled transactions with countries where Denmark has not entered into a double taxation agreement.

Professional and competent advice

We are available with general advice, a review of your documentation, advice on choosing a transfer pricing policy and suggestions for adaptations to your business model.

We see it as our foremost duty to be in ongoing dialogue with our clients and to contribute to minimising the risk of double taxation. We guide our clients on rule changes and provide relevant advice on challenges and opportunities about your exact situation.

Baker Tilly can help you with the following:

• Preparation of transfer pricing policy
• Preparation of transfer pricing documentation (master file and local file)
• Advice on restructuring
• Assistance in connection with tax matters (transfer pricing audit) and assistance in connection with Mutual Agreement Procedures (MAP)
• Identification of permanent establishments and guidance on taxation and duties
• Preparation of database studies (Benchmark)
• Valuation

Contact us and we will help you with transfer pricing.