Denmark enacts new rules on international taxation

On 3 December 2020, the Danish Parliament enacted Bill No. L 28 with changes to:

• Transfer pricing
• Permanent establishments
• Foreign losses

Transfer pricing

The law significantly strengthens the Danish transfer pricing rules as follows:

• Transfer pricing (TP) documentation must be submitted to the tax authorities no later than 60 days after the deadline for the filing of the annual corporate income tax return (generally due six months after year end). This will include both the master file and count…