I. Issue One
Does your tax administration have a published strategy on
the conduct of transfer pricing enquiries/audits (steps, timetable
etc.), and if so what is it?
In recent years, the Danish tax authorities
(''SKAT'') have increased their focus on transfer
pricing as part of their audit activities.
Hence, SKAT's transfer pricing adjustments in 2010 were
Danish Krone 6.6 billion (DKK), in 2009 DKK 15.3 billion and in
2008 DKK 8.7 billion. SKAT has also set up a centralised transfer
pricing audit team, which in 2010 consisted of 80 people.
Each year SKAT publishes a focus area plan. According to the
2011 focus area plan (published on April 6, 2011), the focus on the
loss-making companies or so-called
''zero-tax-companies'' which was initiated by the
project in 2010, continues in 2011. SKAT is focusing on companies
which have had losses for the last three–five years.
Furthermore there is focus on Intellectual Property Rights, in
relation to both royalties,
