Data points
- After the tax return deadline, to file both documentation files[1]
- 60 days
- Cross border controlled transactions below which no written documentation is needed[9]
- DKK 5m
- Base fine per company per income year for late or missing documentation[8]
- DKK 250,000
- Further charge on any income increase from an arm's length adjustment[8]
- 10%
- Consolidated turnover that triggers country by country reporting[7]
- DKK 5.6bn
- How far back an assessment reaches, extended to ten where information was withheld[2]
- 6 years
- Employee ceiling for small and medium group documentation relief[1]
- 250
Denmark files its transfer pricing documentation. Keeping the master file at headquarters and producing it when an auditor asks, which is how most of the world works, does not satisfy Denmark and never has since the rule changed for income years from 2021.
The four facts to know:
- The master file and the local file are both submitted to the tax agency within 60 days of the corporate tax return deadline.
- From income year 2025 a company with cross border controlled transactions under DKK 5 million is out of scope, provided controlled receivables and debt stay under DKK 50 million.
- Documentation may be written in Danish, Norwegian, Swedish or English, so a group's English master file is usable as it stands.
- Late or missing documentation costs DKK 250,000 per company per income year, halved if the file is produced afterwards, plus 10% of any income increase.
Who must prepare transfer pricing documentation in Denmark?
A Danish entity with controlled transactions, where control means more than 50% of share capital or voting rights, or actual control in fact. Small groups and small transaction volumes then get relief from the full documentation duty. The Danish Tax Agency sets out the rules and the reliefs[1] on one page.
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| Criterion | Value for 2026 | Source |
|---|---|---|
| Employee test for small and medium group relief | Fewer than 250 employees | Skattestyrelsen, Denmark |
| Revenue or balance sheet test, as the tax agency states it | Revenue under DKK 391m, or balance sheet under DKK 195m | Skattestyrelsen, Denmark |
| Revenue or balance sheet test, as the OECD states it | Revenue under DKK 250m, or balance sheet under DKK 125m | OECD |
| Cross border de minimis, from income year 2025 | Controlled transactions under DKK 5m, with receivables and debt under DKK 50m | Skattestyrelsen, Denmark |
| Carve out from the small group relief | Transactions with counterparties outside the EU and EEA and outside a treaty still need documentation | Skattestyrelsen, Denmark |
The two threshold sets conflict and both are live. The Danish Tax Agency's own page says DKK 391 million of revenue or DKK 195 million of balance sheet. The OECD country profile for Denmark[2], updated May 2025, says DKK 250 million or DKK 125 million. Both are recorded above. The tax agency's figures are the authority's own current statement, and the lower pair is the safer assumption.
Do I need a master file in Denmark?
Yes, if the group is above the small group relief thresholds and the Danish entity has controlled transactions. Below them, the full obligation does not apply. The tax control law carries the documentation duty[3].
The content follows the standard international template: the group's legal and organisational structure, its business, its intangible assets, its intra group financing, and its overall financial and tax position. The tax agency's legal guide spells the content out[4], so a group master file written for another jurisdiction usually needs checking against that list rather than rewriting.
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What are Denmark's local file requirements?
The local file covers the Danish entity: a description of it, its controlled transactions, the functional analysis, the financial data and the benchmarking. Its scope and its exemptions match the master file exactly, so a company inside the relief owes neither and a company outside it owes both.
The local file is a separate submission, filed alongside the master file rather than held. Neither a preference for local comparables nor a refresh cadence for the benchmarking set is confirmed from a primary source, so this page states neither.
When is Denmark transfer pricing documentation due?
Within 60 days of the corporate tax return filing deadline, for income years beginning on or after 1 January 2021. The return itself falls six months after the year end, so a 31 December 2025 year end puts the return around 30 June 2026 and the documentation roughly 60 days after that. If the return deadline is extended, the documentation deadline moves with it.
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| Obligation | Deadline | Source |
|---|---|---|
| Master file and local file, both filed | Within 60 days of the tax return filing deadline | Skattestyrelsen, Denmark |
| Controlled transactions disclosure | With the corporate income tax return | Skattestyrelsen, Denmark |
| Country by country notification | Before the end of the income year | Skattestyrelsen, Denmark |
| Country by country report | 12 months after the fiscal year end | Skattestyrelsen, Denmark |
What language can the documentation be in?
Danish, Norwegian, Swedish or English. The documentation order that took effect for income year 2025[5] confirms it, and the tax agency asks for a translation only where one is specifically necessary. An English master file written by a foreign parent therefore works as it stands, which removes the usual translation lead time and leaves the 60 day clock as the only real constraint. Whether amounts must be presented in Danish kroner or in a functional currency is not confirmed from a primary source, so this page states no rule on it.
Which Danish tax return fields disclose controlled transactions?
Every tax liable legal entity with controlled transactions completes fields 503, 505a, 542 and 542a in the corporate income tax return. Hydrocarbon tax companies use form 05.022 instead. The disclosure travels with the return, months before the documentation itself is due, and the tax agency publishes the appendix[6] that carries it.
What are Denmark's country by country reporting requirements?
Country by country reporting applies to a multinational group with consolidated turnover of DKK 5.6 billion or more in the income year. The Danish Tax Agency publishes the rules[7]. The report is due no later than 12 months after the fiscal year end.
The notification is the part that catches groups out, because it runs on a different clock. A Danish constituent entity tells the tax agency before the end of the income year which group entity will file the report and in which jurisdiction. In a joint taxation group the management company makes that notification for the others. The regime has applied to income years beginning on or after 1 January 2016.
What are the penalties for getting Denmark transfer pricing wrong?
The base fine is DKK 250,000 per company per income year where documentation is late or missing and the failure was deliberate or grossly negligent. It halves to DKK 125,000 if adequate documentation is produced afterwards, and a further 10% of any income increase applies on top of either figure.
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| Trigger | What it costs | Source |
|---|---|---|
| Late or missing documentation, deliberate or grossly negligent | DKK 250,000 per company per income year | Skattestyrelsen, Denmark |
| Adequate documentation produced afterwards | Reduced to DKK 125,000 | Skattestyrelsen, Denmark |
| Income increase from an arm's length adjustment | A further 10% of the increase | Skattestyrelsen, Denmark |
The tax agency's legal guidance sets the fines out[8]. Assessments reach back six years from the end of the income year, and ten years where information was withheld intentionally or through gross negligence, so a single missed year stays open far longer than the fine suggests.
What does a foreign parent need to do for its Danish subsidiary?
Five things, in order. File the country by country notification naming the parent as the filer. Localise the group master file against the Danish content list. Prepare the Danish local file, in English if that is easier. Submit both within 60 days of the Danish return deadline. Complete the controlled transactions fields in the return itself.
The 60 day clock binds the Danish entity whatever the parent does and wherever it sits. The de minimis relief from income year 2025[9] is the one route out, and it does not cover intangible asset transactions or counterparties in states that do not exchange tax information with Denmark.
How does Denmark differ from the OECD baseline?
On one point sharply and on three points softly. The international model is prepare and produce on request. Denmark requires active submission on a statutory 60 day clock, and that single difference is what foreign parents get wrong.
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| Area | Denmark's position | Source |
|---|---|---|
| Filing model | Both files are submitted within 60 days of the return deadline, not held for a request | Skattestyrelsen, Denmark |
| Language | Danish, Norwegian, Swedish or English all accepted | OECD |
| Low value adding services | A simplified approach is available | OECD |
| Advance pricing agreements | Unilateral, bilateral and multilateral all available. Fees and terms not confirmed | OECD |
How we help with Denmark transfer pricing
Denmark's 60 day clock is the trap, and it starts from a return deadline that moves. We build the benchmarking and the functional analysis, localise the group master file against the Danish content list, write the local file, and file both inside the window alongside the controlled transactions fields in the return. See how our transfer pricing software works.
Book a demo to map your Danish master file and local file obligations before the next filing window opens.
Official sources
9 sources
- 1.Skattestyrelsen, Denmark. Transfer pricing
- 2.OECD. Transfer pricing country profile: Denmark (May 2025)
- 3.Folketinget, Denmark. Act No. 1535 of 19 December 2017, the Tax Control Act
- 4.Skattestyrelsen, Denmark. Legal guidance on master file and local file content
- 5.Skatteministeriet, Denmark. Executive Order No. 883 of 24 June 2025 on transfer pricing documentation
- 6.Skattestyrelsen, Denmark. Controlled transactions appendix to the income tax return
- 7.Skattestyrelsen, Denmark. Country by country reporting
- 8.Skattestyrelsen, Denmark. Legal guidance on transfer pricing penalties
- 9.Skattestyrelsen, Denmark. Legal guidance on the de minimis relief from income year 2025
Article by
Sam Suechting
Head of Product, Commenda
Sam is a seasoned expert in sales tax, leading Commenda's effort to build the worlds most comprehensive database of global tax rules and business regulations. At Silverhaze Partners, he worked in early-stage venture capital, where he saw firsthand how tax complexity and regulatory friction hold back startups from scaling internationally. That experience now powers his work at Commenda-bringing clarity, precision, and real-world insight to one of the most frustrating parts of doing business globally.
Disclaimer: Commenda and its affiliates do not provide tax, accounting, or legal advice. This material has been prepared for informational purposes only, and is not intended to provide or be relied on for tax, accounting, or legal advice. You should consult your own tax, accounting, and legal advisors before engaging in any related activities or transactions.
