You must submit the mandatory transfer pricing documentation
Dear Sir or Madam
You have stated in your tax return that you are subject to the obligation to prepare transfer pricing documentation for the 2025 income year. This means that you must prepare and submit the mandatory transfer pricing documentation no later than 60 days after the deadline for submitting your tax return.
How to submit the documentation
Please submit the documentation in our self-service system E-tax for businesses (Tastselv Erhverv).
Log on at skat.dk/tastselverhverv > Tax for companies etc. > Corporation tax > Corporation tax > Transfer pricing documentation. Here, you can also see your deadline for reporting the transfer pricing documentation.
Have the following ready when submitting the documentation
You need to submit at least one local file and one master file for each income year:
- One electronically readable local file describing the company subject to the documentation requirement and the controlled transactions, which the company is involved in.
- One electronically readable master file describing the entire group.
You will find the specific documentation requirements in sections 4 and 5 of Danish Executive Order no. 883 of 24 June 2025.
A change in legislation means that the obligation to provide transfer pricing documentation will be relaxed from the 2025 income year onwards, including for companies with small cross-border controlled transactions. You will no longer need to submit transfer pricing documentation for dividends and other one-sided corporate law transactions. You can read more about the relaxed documentation requirements at skat.dk/transfer-pricing-english.
Documentation obligation indicated on tax return
This letter has been sent automatically because you have stated in your tax return that you are subject to the transfer pricing documentation obligation.
If you believe that your company’s documentation obligation is due to an error in your tax return, please request a reopening of your company’s tax return to correct the error.
How to request a reopening
- You can request for your tax return to be reopened in E-tax for businesses.
Log on at skat.dk/tastselverhverv > Tax for companies etc. > Corporation tax > Corporation tax > Tax return. - Select the correct income year and click ‘Change display’.
- Click on ‘Request a reopening of your tax assessment’.
- Complete and send your request with attached appendices/calculation and your reasons.
Go back to the tax return form to submit the changed information.
Consequences of late submission or non-submission
If you do not submit the mandatory transfer pricing documentation (whether intentionally or through gross negligence), your company may receive a penalty. The penalty for failing to submit complete transfer pricing documentation by the deadline is DKK 250,000 per company per income year plus 10% of any increase in taxable income.
If you submit complete transfer pricing documentation after the deadline, the penalty may be reduced to DKK 125,000 per company per income year plus 10% of any increase in taxable income.
You must submit the documentation yourself – or authorise others to do so
Please note that your company is independently required to submit transfer pricing documentation.
If your management company is to submit transfer pricing documentation on your behalf, you need to authorise them via E-tax for businesses: skat.dk/authorise-accountant.
Legislation and statutory rules
The rules on transfer pricing and documentation are set out in sections 37-46 of the Danish Tax Control Act (Skattekontrolloven).
The rules on the relaxed documentation requirement are set out in Act no. 750 of 20 June 2025.
The rules specifying what transfer pricing documentation must contain are set out in Executive Order no. 883 of 24 June 2025.
The rules stating that you must prepare and submit mandatory transfer pricing documentation within 60 days of the deadline for filing your tax return form are set out in section 39(3) of the Tax Control Act.
The rules stating that companies may receive a penalty if they intentionally or through gross negligence fail to submit the mandatory transfer pricing documentation no later than 60 days after the filing deadline are laid down in section 84(5) of the Tax Control Act.
For clarification of the types of documentation you must submit, please see our Danish-language legal guide, section C.D.11.13 ‘Transfer pricing dokumentationspligt og land for land-rapporteringspligt’ (Transfer pricing documentation requirement and country-by-country reporting obligation).
You will find the Tax Control Act at skat.dk/skattelove (in Danish). Our Danish-language legal guide is available at skat.dk/juridiskvejledning. Executive orders can be found at retsinformation.dk by searching for the number and year.
Any questions?
You can read more about transfer pricing documentation and how to submit it at skat.dk/transfer-pricing-english.
If you have any questions, please write to us by logging on at skat.dk/tastselverhverv and selecting Contact > Write to us > Companies and foundations > Transfer pricing or call us on (+45) 72 22 28 82.
Yours faithfully
Danish Tax Agency