Mandatory reporting of transfer pricing documents

Accounting | 27.05.2024

by Nils Jeppesen

Transfer pricing rules in Denmark are essential for many companies, including various corporations and other registered taxable entities that operate with affiliated entities. The law was updated in 2021, imposing stricter requirements for the annual reporting of transfer pricing documents. 

Would you like to know more about why the legislation was updated in 2021? Read more about it in this article. 

In this article, we will focus on the specific requirements and exceptions related to the documentation obligation. Additionally, we will outline the key deadlines and potential penalties for non-compliance. 

Continue reading to gain a deeper understanding of transfer pricing legislation and how it affects your business.

Companies subjected to the requirements   

The documentation requirements are applicable for all corporate tax liable entities that takes part in a transaction with a related company. This could possibly be between companies in the same group. 

However, the Danish entity of your company could be exempted from the documentation requirements, if the group it has less than 250 employees and further, less than either 

  • 125 million DKK in total assets 
  • or less than: 250 million DKK in total revenue per year. 

Note: The taxable entity is still required to provide documentation if it has transactions with a related entity based in a country lacking a double taxation agreement that governs transfer pricing. Consequently, the documentation submission requirements remain in force.

What is transfer pricing (TP)? 

Related companies often engage in transactions with each other. These transactions must be executed as if they are done with independent companies. This means that the prices contract terms and other aspects of the transaction must be set as if negotiated between independent parties. 

Groups have to obtain information on prices and contract terms from transactions outside their own organization as a main rule.    

This regulation is also referred to as the arm’s length principle.

Content of the transfer pricing documents 

The transfer pricing documents consist of two files. The relevant entities, subjected to the requirements, must submit a master file covering the transfer pricing policies and other information for the entire group and a local file covering the Danish entity including an assessment that states if the arm’s length principle has been complied with during the tax year. The files must also include appendices to proof that transfer pricing policies are adopted in practice. 

Transfer pricing memorandums or other transfer pricing reports are not sufficient to fulfil the document requirements.


The deadline for submitting the transfer pricing documents is the 60 days following the deadline for submitting the corporate tax return. For entities using the calendar year as the tax year the deadline is August 29th. 

It is possible to apply and obtain an extension of the deadline for submitting the master file, but the authorities have been reluctant to allow an extension on the deadline for the local file.



The penalty for not submitting the transfer pricing documents before deadline is a fine starting at 250,000 DKK for every year the documents have been submitted late. The fine can be reduced to 125,000 DKK if the documents are submitted after the deadline, and they are approved as sufficient.


If you are in need of more information or have any questions or concerns, you are welcome to contact us. 

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About Nils Jeppesen

Nils Jeppesen handles compliance related to anti-money laundering measures and data protection law, as well as legal advising within corporate and tax law.