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Transfer pricing

All trading between undertakings in the same group must take place according to the arm’s length principle (which means that the price agreed must be the same as the price that would be agreed in a comparable transaction between two unrelated parties), and both subsidiaries and the parent company must be able to document this in transfer pricing documentation. The same applies between main shareholders and their companies, and between parties liable to pay tax and their permanent establishments.

The rules concerning written documentation and the disclosure obligation for controlled transactions can be found in Part 4 of the Danish Tax Control Act (Skattekontrolloven). 

On this page you can read more about who, for income years starting on or after 1 January 2021, has to submit written documentation and when this documentation must be submitted.

You can also read about the full and limited documentation obligation - and you can find guidance on the correct preparation and submission of the documentation.

For further legal information in Danish see our legal guide .