Denmark Transfer Pricing Documentation Requirements

Denmark is one of the few jurisdictions that requires transfer pricing documentation to be filed rather than simply retained and produced on request. The combined Master File and Local File must be submitted within 60 days of the tax return due date, and a failure to meet that deadline is treated by default as gross negligence.

Master FileLocal FileCbC report

Last reviewed 2025

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Requirements at a glance

RequirementThresholdDeadlineDeadline typeLanguagePenalty
Master File
Required
Group ≥ 250 employees, or balance sheet > DKK 125m, or turnover > DKK 250m60 days after tax return due dateSubmission deadline
The documentation must be filed with the tax authority by the date shown.
EN / DA / NO / SVYes (late = gross negligence)
Local File
Required
Same size limits as Master File60 days after tax return due dateSubmission deadline
The documentation must be filed with the tax authority by the date shown.
EN / DA / NO / SVYes
CbC report
Required
Group revenue ≥ DKK 5,600mLast day of reporting periodSubmission deadline
The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately.
—Yes
Preparation deadline: documentation must exist by the date and is produced only on request.   Submission deadline: filed with the authority by the date.
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A mandatory filing regime

Denmark departs from the approach taken across most of Europe, where documentation is retained and produced only when requested. For income years beginning on or after 1 January 2021, the full documentation package, comprising the Master File and the Local File, must be filed within 60 days of the tax return due date. The corporate income tax return is generally due six months after the financial year-end, and in no case later than 1 September.

The deadline therefore constitutes a fixed compliance obligation rather than a contingent one. Both documents must still be prepared on a contemporaneous basis. A size exemption is available: a group that, together with its affiliated companies, has fewer than 250 employees and either a balance sheet total below DKK 125 million or turnover below DKK 250 million may fall outside the full documentation obligation.

Distinctive features of the Danish regime

Two features distinguish Denmark from comparable jurisdictions. The first is the combination of a firm 60-day filing deadline with a strict penalty position, under which a missed deadline is treated by default as gross negligence. The second is that penalty exposure is not limited to late filing. Documentation submitted within the deadline may still attract a penalty where it fails to meet the formal content requirements, so both the timeliness and the substantive quality of the filing carry risk. Documentation may be prepared in English, Danish, Norwegian, or Swedish, which affords greater flexibility than many jurisdictions permit.

Benchmarking and comparables

Local comparables are not required, and pan-European benchmarks are accepted. Multi-year testing is generally accepted, although it is not invariably given full weight, and for principal structures the documentation is expected to demonstrate whether the margins of limited-risk entities fall within an arm’s length range. The frequency of fresh searches and roll-forward updates follows OECD guidance. The limitation period for a transfer pricing assessment extends to 1 May of the sixth year following the financial year concerned.

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Frequently asked questions

Can a taxpayer be penalised in Denmark even if documentation is filed on time?

Yes. Documentation filed within the deadline may still attract a penalty if it does not meet the formal content requirements, in addition to any penalty for late filing.

When is the corporate income tax return due in Denmark?

It is generally due six months after the financial year-end, and in no case later than 1 September. The 60-day documentation deadline runs from that return due date.

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This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.