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Denmark Planning to Implement New Transfer Pricing Documentation Requirements including CbC Reporting

28 September 2015

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Proposed Changes

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Denmark

According to recent reports, the Danish government has drafted legislation for the implementation of new transfer pricing documentation requirements, including country-by-country (CbC) reporting. The requirements are in line with the guidance developed as part of Action 13 of the OECD BEPS Project. Danish multinational groups with consolidated revenue of at least DKK 5.6 billion would be required to submit the CbC report to the Danish tax authority. If the ultimate parent is a Danish tax resident, the parent submits the report. If the ultimate parent is not a Danish tax resident, a Danish subsidiary of the group would be required...