Worldwide transfer pricing reference guide 2014

Denmark (continued)
Expected reaction to OECD Report on BEPS
During 2013 the OECD published a discussion paper and later in the year an Action Plan with a view to address the perceived flaws in the
international tax rules including the following subjects:
Traditionally, Denmark has followed the advice of the OECD, and most of Denmark’s double tax conventions are built on the OECD
Model Tax Convention. It is therefore expected that Denmark will follow the advice of the OECD, and the amendments to the Model Tax
Convention as a result of the Action Plan on BEPS.
The country-by-country reporting and the Masterfile documentation in particular, could lead to changes in domestic law regarding what
is required in order to be compliant with Danish transfer pricing requirements, since these requirements focus mostly on documentation
regarding operations in Denmark, and does not take on the holistic view that the OECD is planning along with the action plan.
Regarding IP, it should be noted that historically, the Danish tax authorities have been focusing on the transfer pricing area including
international transfer of IP rights. As mentioned above, it is expected that Denmark will follow the amendments to the Model Tax
Convention, and also any amendments to the OECD Guidelines, should it arise.
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