The Danish tax authority has issued a notice on a change in practice in relation to the requirement that transfer pricing (TP) documentation for a year must be available in its entirety by the tax return deadline.
Previously, the tax authority's general practice was that if TP documentation was not available by the tax return deadline, then a discretionary assessment could be issued. However, the Supreme Court ruled in a case involving Microsoft ({News-2019-02-04/A/3-previous coverage}) th…