Transfer pricing: Dokumentationskravene i Danmark samt i EU

Chris Marker

Student thesis: Master thesis


The main objective of this thesis is to analyze the documentation requirements for Danish corporations operating in multinational Enterprises. The secondary objective is to analyze the existing guidelines on transfer pricing issues on the EU level. Transfer pricing is defined by pricing of controlled transactions. During the past years, transfer pricing has become one of the most important topics in the field of international taxation. This is due to an increased globalization and an increased number of cross-border controlled transactions, especially within the EU internal market. This is especially interesting for tax authorities as multinational enterprises might be tempted to relocate their income to the country with the lowest tax on company income. The Danish tax authorities has made a very detailed guideline, containing the requirements for transfer pricing documentation. The guideline describes in detail, the 5 topics that must be documented, if the tax authorities should decide to perform a transfer pricing audit. On an EU level, the EU Joint Transfer Pricing Forum has issued guidelines on several transfer pricing issues, including a guideline on documentation requirements and a guideline for best practice regarding Advance Pricing Agreements (APA’s). The opinion of the forum is that the documentation requirements should be made more standardized and transparent across Europe, hereby reducing compliance costs for corporations and also making the tax audits easier for tax authorities. The forum considers APA’s as the best tool available today, for avoiding double taxation issues between European tax authorities, and the guideline issued by the forum contains detailed information on best practice regarding APA’s.

EducationsMSc in Auditing, (Graduate Programme) Final Thesis
Publication date2009
Number of pages87