Failure To Submit Danish Transfer Pricing Documentation?

Generally, Danish companies are obligated to prepare and file transfer pricing documentation if they are part of a group with over 250 employees and either:

• a balance sheet of DKK 125 million or more, or
• an annual revenue of DKK 250 million or more.

The thresholds are calculated at group level (i.e. consolidation of the financials and number of employees of all entities in the group, Danish and foreign).

If the obligation to prepare transfer pricing documentation applies, such documentation must be prepared and filed with the Danish Tax Agency no later than 60 days after submission of the Danish income tax return.