Bill enacted: Danish government initiatives to tighten the grip on multinational enterprises

Tax Insights ()

The Danish Government has enacted the bill to tighten the grip on multinational enterprises (MNEs), as described in the PKN of 25 May 2012.

The new legislative changes will become effective from 1 July 2012, however the auditor’s report and the Danish Tax Authorities’ (DTAs) discretion to make public all companies’ taxable income and tax payments will become effective from 1 January 2013. The transfer pricing (TP) related initiatives have retrospective effect for any tax period that remains open for TP tax audits. This means that, from 1 January 2013, the DTA can request an auditor’s report on TP documentation covering the years 2007 – 2011 with 2007 being closed for tax re-assessment as of 2 May 2013.