Skip to main content

Last Year’s Master File Still Has Merit in Denmark

February 22, 2022

Transfer Pricing in Denmark

When it comes to transfer pricing, Denmark is strict but it’s not unreasonable.

Sure, the government enacted supplemental transfer pricing legislation in November 2021, requiring taxpayers to not just prepare documentation, but to submit it. Given that you were preparing it anyway, that’s not much of a problem.

However, for taxpayers the new deadline seems a little tight—60 days within the due date of filing the return—especially when you consider the new laws require filing for fiscal year 2021.

Danish Tax Authorities

Well, it seems like the Danish tax authorities could see that was a big ask. So, on January 31, 2022, they released new guidance, which allows taxpayers a little wiggle room.

  • Taxpayers who are running late on the master file and won’t make the submission deadline are allowed to submit last year’s master file—so long as it’s less than a year old.
  • In that situation, taxpayers would also have to describe relevant changes to entities that aren’t noted in the local file.

All of which, like we said, seems perfectly reasonable.