According to recent reports, the Danish government has drafted legislation for the implementation of new transfer pricing documentation requirements, including country-by-country (CbC) reporting. The requirements are in line with the guidance developed as part of Action 13 of the OECD BEPS Project.
Danish multinational groups with consolidated revenue of at least DKK 5.6 billion would be required to submit the CbC report to the Danish tax authority. If the ultimate parent is a Danish tax re…