Transfer Pricing in Denmark is entering a new phase of transparency and technical complexity. Recent legislative updates expand Country-by-Country (CbC) reporting disclosures under EU DAC9 and refine Denmark’s Pillar Two minimum tax framework, bringing tighter alignment with OECD administrative guidance.
For multinational enterprise (MNE) groups with Danish entities, these changes go well beyond form-filling. They directly affect data governance, entity identification, intercompany consistency, and audit readiness.
This guide explains what has changed, why it matters, and how groups should respond — in clear, practical terms.
Why These Denmark Transfer Pricing Updates Matter
Denmark has long been viewed as a high-compliance, low-tolerance jurisdiction. The latest updates reinforce that position by:
- Expanding the scope and depth of CbC reporting
- Increasing traceability of constituent entities
- Tightening interaction between Transfer Pricing, Pillar Two, and statutory data
- Reducing room for inconsistency across filings
Strategic signal: Danish tax authorities are prioritizing data integrity and cross-regime consistency, not just pricing outcomes.
Expanded CbC Reporting Under EU DAC9
Denmark has amended its CbC reporting rules to align with EU DAC9, significantly increasing the entity-level detail required from multinational groups.
What Has Changed?
CbC Table 2 must now include enhanced identifiers for each constituent entity, such as:
- Full legal entity name
- Tax jurisdiction of residence
- Local registration numbers (CVR / SE)
- Foreign tax identification numbers
- These changes apply across the group — not only to Danish entities.
Why This Is Important for Transfer Pricing
While CbC reporting is often viewed separately from Transfer Pricing documentation, Danish practice increasingly treats them as connected risk indicators.
Misalignments between:
- CbC data
- Local Transfer Pricing files
- Master File disclosures
can now be more easily detected and challenged.
What This Means for Multinational Groups
The expanded CbC scope introduces new operational and compliance pressures, particularly for complex group structures.
Key implications include:
- Greater need for entity master data accuracy
- Increased exposure where legal structures have evolved but documentation has not
- Higher scrutiny of entity roles vs reported profits
- Reduced tolerance for “legacy” inconsistencies in older filings
Practical takeaway: Denmark is using DAC9 to improve audit targeting — not just transparency.
Pillar Two Amendments: Denmark Tightens the Framework
Alongside DAC9 changes, Denmark has amended its Minimum Taxation Act to align with updated OECD Pillar Two administrative guidance.
These amendments clarify and refine how the global minimum tax applies in specific scenarios.
Key Pillar Two Clarifications You Should Not Ignore
International Joint Taxation
The updated rules provide clearer guidance on how jointly taxed entities are treated for Pillar Two purposes.
Why this matters:
Incorrect treatment can distort effective tax rate (ETR) calculations
Errors may cascade into top-up tax exposures
Transfer Pricing assumptions may need recalibration where joint taxation alters profit attribution
Deferred Tax Liabilities
Denmark has clarified how deferred taxes interact with Pillar Two computations.
This affects:
- Timing differences in ETR calculations
- Recognition of deferred tax assets and liabilities
- Alignment between financial reporting and tax modeling
For Transfer Pricing teams, this reinforces the need to coordinate with finance and accounting functions — silos increase risk.
Securitization Entities Brought Into Focus
New provisions address securitization entities, which are often overlooked in Transfer Pricing and Pillar Two planning.
Implications include:
- Reassessment of entity classification
- Review of profit allocation logic
- Confirmation that pricing outcomes align with Pillar Two substance expectations
Warning: Structures once considered peripheral may now fall squarely within Pillar Two analysis.
How These Changes Affect Transfer Pricing Risk in Denmark
Taken together, the DAC9 and Pillar Two updates signal a broader shift in Denmark’s approach to Transfer Pricing oversight.
Expect to see:
- More data-driven audit selection
- Cross-checking of CbC, Master File, and local file disclosures
- Increased challenges where entity characterization lacks substance
- Less patience for documentation that explains outcomes but not why
Transfer Pricing in Denmark is no longer just about arm’s length margins — it’s about coherence across regimes.
Action Checklist for Multinationals With Danish Operations
- Now is the right time to reassess your Denmark exposure. Smart next steps include:
- Validating entity identifiers across CbC, Transfer Pricing, and statutory filings
- Stress-testing Transfer Pricing policies against Pillar Two outcomes
- Reviewing joint taxation and securitization structures
- Ensuring deferred tax assumptions align across teams
- Updating documentation to reflect current operational reality
Early action reduces both audit risk and remediation cost.
How TransferPricing.report Supports Denmark-Focused Compliance
At TransferPricing.report, we help multinational groups navigate Transfer Pricing and Pillar Two developments in Denmark with precision and practicality.
Our Denmark-focused support includes:
- Transfer Pricing documentation aligned with DAC9 expectations
- CbC and Master File consistency reviews
- Pillar Two impact assessments integrated with Transfer Pricing models
- Entity characterization and FAR analysis
- Audit-ready documentation and advisory support
We focus on defensible outcomes, not generic templates.
Final Thought: Denmark Is Raising the Bar — Quietly but Firmly
Denmark’s updates may appear technical, but their impact is strategic. Groups that treat DAC9 and Pillar Two as isolated exercises risk misalignment, audit challenges, and unexpected tax exposure.
- Operating in Denmark?
- Unsure whether your Transfer Pricing and CbC data still align?
Talk to our Transfer Pricing specialists and bring clarity to your Denmark compliance strategy.
In Denmark, precision isn’t optional — it’s expected.
This is general information only and not professional advice. Consult a professional before acting.
