Transfer prices – increasingly contentious
– new valution guidelines
The Danish tax authorities have increased their focus on
transfer pricing and the area is becoming ever more contentious,
giving rise to some of the largest ever Danish tax cases.
Meanwhile, the tax authorities have issued new valuation
guidelines.
Increasing transfer pricing adjustments
According to recently published figures, the Danish tax
authorities are increasing revenues from transfer pricing
audits.
In 2009, 32 adjustments were made with adjustments totalling DKK
15.3 billion.
The figures for the period 2005 - 2009 are as follows:
Denmark's newly appointed Minister of Taxation, Mr. Troels
Lund Poulsen, has announced even more transfer pricing audits of
multinational groups. According to a top civil servant in the
Danish Ministry of Taxation, this approach may very well lead to
more transfer pricing litigation, as the Danish Tax Authorities
will test the boundaries of the
