Join us in Amsterdam on Sep 24 & 25 for the ITR Transfer Pricing Forum 2025
Denmark continues to be a front-runner in global transfer pricing regulations, maintaining a structured compliance regime for multinational enterprises (MNEs) operating within or through the country. In June 2025, the Danish Parliament enacted important reforms to its transfer pricing documentation framework, easing requirements for many companies and introducing clearer thresholds for full or limited compliance.
This blog unpacks the updated rules, clarifies the new thresholds for transfer pricing compliance, and highlights what MNEs need to consider when planning their documentation strategy under the arm’s length principle.
Before the 2025 update, Denmark required all Danish companies and permanent establishments engaged in intercompany transactions with related foreign entities to maintain comprehensive TP documentation. These rules ensured that the price charged for goods or services met the market price standard set by the arm’s length transfer pricing framework.
Documentation typically had to be submitted annually to the Danish Tax Agency, no later than 60 days after filing the annual corporate tax return.
| Criteria | Threshold (Pre-2025) | Requirement |
|---|---|---|
| Employees | 250 or more | Full documentation required |
| Annual Turnover | DKK 250 million or more | Full documentation required |
| Balance Sheet Total | DKK 125 million or more | Full documentation required |
Entities below these thresholds faced limited documentation obligations, particularly for controlled transactions between Danish-resident companies or majority shareholders.
Effective for fiscal years beginning in 2025, companies are exempt from documentation if:
This provides relief to smaller companies with relatively low exposure to intercompany pricing activities.
For entities operating within a global corporate group, full documentation is now only required if the group collectively exceeds:
These changes align with efforts to focus compliance on higher-risk entities and transactions with greater cross-border complexity.
Some party transactions are now explicitly excluded from the documentation requirement, including:
However, transactions with non-EU/EEA countries that do not have a double taxation agreement with Denmark remain subject to full documentation.
Additional simplifications include:
| Criteria | Threshold (2025) | Requirement |
|---|---|---|
| Employees | 250 or more | Full documentation required |
| Annual Turnover | DKK 391 million or more | Full documentation required |
| Balance Sheet Total | DKK 195 million or more | Full documentation required |
| Controlled Transactions Value | Below DKK 5 million | Exempt from documentation |
| Intra-group Receivables/Debts | Below DKK 50 million | Exempt from documentation |
For multinational corporations operating in Denmark, the 2025 reforms offer a more tailored compliance landscape. Approximately 1,500 companies are expected to be relieved from full transfer pricing documentation burdens. However, companies must still ensure:
The changes are in line with Denmark’s broader aim of improving tax administration efficiency while maintaining oversight of cross-border transfer pricing methodology.
Navigating Denmark’s updated transfer pricing regulations can be complex, especially for companies dealing with hundreds of cross-border transactions in question each year. Reptune’s intelligent TP platform automates your documentation and compliance workflows, helping you:
With Reptune, proactive documentation becomes a strategic advantage rather than an administrative burden.
Denmark’s 2025 transfer pricing reforms mark a significant move toward simplification and proportional compliance. By raising documentation thresholds and introducing smart exemptions, Denmark reduces pressure on lower-risk taxpayers while reinforcing focus where it matters most.
For multinational enterprises, the changes offer a chance to recalibrate TP strategies and embrace digital solutions that keep pace with evolving tax authority expectations.
