Denmark Updates Guidance on Transfer Pricing Documentation

The Danish Tax Administration has published updated guidance on transfer pricing documentation, which is dated 31 January 2022. This includes two key updates.

The first update concerns the changes introduced by Law no. 2194 of 30 November 2021, including that controlled transactions between Danish companies are generally exempt from the documentation requirements unless one party is subject to different taxation, such as the special tax rules under the Tonnage Tax Act or the Hydrocarbon Tax…