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Danish High Court Rules on Transfer Pricing for Software Marketing Activities and Discretionary Assessment for Non-Contemporaneous Documentation

|Approved Changes|Denmark
Denmark

On 28 March 2018, the Danish Eastern High Court issued a decision concerning whether a commission agreement for marketing software in Denmark can be extended to computers using the software, and whether a lack of contemporaneous transfer pricing documentation can result in a discretionary assessment. The case involved Microsoft Denmark ApS, which received commission fees under an agreement for…

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