On 31 March 2014, the Danish tax authorities published their Transfer Pricing report for 2013. The report contains an overview of transfer pricing corrections made by the Danish tax authorities. In 2013, the Danish tax authorities adjusted the taxable income of 77 Danish companies. These corrections amounted to well over EUR 2 billion.
According to the Danish tax authorities, 74% of these corrections are related to intellectual property rights and 21% of the corrections are related to companies with losses. These numbers clearly reveal the focus of the Danish tax authorities’ transfer pricing audit strategy: companies that transfer intellectual property rights, intra-concern royalty flows and companies that have or are making losses. It is therefore recommended that multinational enterprises with activities in Denmark closely monitor the quality of their transfer pricing documentation especially if they are involved in transactions concerning intellectual property rights or making losses.