The Danish Ministry of Taxation has published a draft bill introducing key updates to transfer pricing (TP) requirements. Here are the highlights:
Threshold Adjustments
The group revenue threshold would increase from DKK 250M to DKK 391M, and total assets from DKK 125M to DKK 195M, aligning with the EU’s updated definition of large groups.
-The threshold of 250 full-time group employees remains unchanged.
Exemptions from Documentation Requirements
Taxpayers may be exempt from preparing TP documentation if:
• Total controlled transactions are below DKK 5 million per year, and
• Intercompany balances are below DKK 50 million.
Additionally, exemptions apply to certain equity-related transactions (e.g., dividends, capital increases) and passive capital placements.
These exempt transactions are not counted toward the DKK 5M / 50M thresholds.
Documentation Still Required
TP documentation is still mandatory for:
• Transactions involving intangible assets (as defined under Section 40 of the Danish Depreciation Act), and
• Transactions with non-EU/EEA jurisdictions that do not exchange tax information with Denmark.
OECD Ammount B Implementation
Denmark intends to adopt the OECD’s Amount B for baseline distribution activities — but only for transactions with countries that also implement Amount B (e.g., Mexico, Brazil, Thailand).
📅 If passed, the changes will apply to income years beginning 1 January 2025 or later.
For more information: Daniel.medvedovsky@basefirma.com