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Denmark: Record breaking Transfer Pricing adjustment in Denmark

The Danish tax authorities have, for the third year in a row, increased the taxable income of multinational groups with a record-breaking amount. The latest years’ audit results in 20 billion DKK:

The Danish tax authorities have, for the third year in a row, increased the taxable income of multinational groups with a record-breaking amount.

According to this statistic, the work of the authorities has been very succesful. The total number of finalised tax audits (year/number) are:

2008 2009 2010 2011 2012 2013 2014
27 32 40 47 67 77 76

The Ministry of Taxes has explained that the largest adjustments on the taxable income in Denmark are related to the transfer of intangible assets. There is also a decrease of the income in 2014. In a total of 16 cases the Danish income has been reduced with a total of 5.4 billion DKK. This is a result of corresponding adjustments (increases) of the taxable income in other countries.

The Danish tax authorities states that the focus in 2015 will be on a better dialog and collaboration with multinational groups, e.g. via the new Tax Governance concept. Under the Tax Governance concept, the authorities will work closely with some of the largest company groups to identify tax risks upfront in order to agree on internal pricing at an earlier stage and so avoid large changes at a later point.

With such 'great results', it is expected that the Danish authorities will keep up the pace in 2015 and the years to come.

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