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Denmark adopts new rules relaxing transfer pricing documentation requirements for domestic controlled transactions and addressing the application of benchmarking

|Tax Alerts, National/Federal Taxation, Transfer Pricing|Denmark
Denmark

On 25 November 2021, the Danish Parliament adopted bill No. L7 which to a large extent abolishes the requirement to include domestic controlled transactions in transfer pricing (TP) documentation.

The bill also specifies the requirement to apply appropriate benchmarking in the comparability analysis.

The bill will be effective for income years starting 1 January 2021 or later.

The Bill

Domestic controlled transactions

According to the bill, TP documentation is no longer required for transactions betw…

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