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      Transfer Pricing is a fundamental concept in international business, involving the pricing of transactions between related entities within a multinational corporation. These transactions can include goods, services, or intellectual property. The aim is to ensure these transactions are at arm's length, reflecting terms agreed upon by independent parties in similar situations.

      Transfer Pricing continues to be a top focus area for tax authorities and multinational enterprises around the world. Many countries have introduced ever more stringent transfer pricing regulation, including significant penalties for non-compliance, supported by OECD guidance and policy papers. This, combined with the increasing number of audits and disputes both with and between tax authorities, makes it more important than ever that multinational enterprises are diligent in determining their transfer pricing policies, and are able to document that all controlled transactions are conducted in accordance with the arm's length principle.

      Acknowledged as leading experts in Transfer Pricing practices

      Our Transfer Pricing team consists of some of Denmark's most well-renowned and experienced specialists, and we are acknowledged for mastering global challenges, being innovative, forward-thinking and client centric with quality and timely delivery in focus. We focus on understanding our clients in every corner of their business so that we can turn knowledge and planning into value.

      Simon Schaadt

      Partner, Transfer Pricing

      KPMG Acor Tax in Denmark


      What we do

      Our approach enhances efficiency and compliance, ensuring that transfer pricing strategies are both effective and future-proof, helping businesses thrive in a competitive global market.

      transfer pricing team

      Transfer Pricing documentation is the reports, in the format of a local file and a master file, which documents the arm’s length nature of intra-group transactions.

      By leveraging automation, we assist in preparing your documentation and ensure it complies with Denmark's mandatory submission requirements, minimizing audit risks and efficiently achieving regulatory standards.

      Value chain management supports in managing complex tax considerations across the value chain to ensure alignment between tax and business operations.

      We help analyze and restructure value chains to minimize tax leakage, align tax strategies with business goals, mitigate risks, and protect your reputation.

      Arm's Length analysis and benchmarking ensure intra-group transactions comply with market price and terms by comparing them to similar independent transactions, supporting compliance with the arm's length principle. We perform detailed analyses to ensure goods, services, royalties, and financial transactions adhere to the arm's length principle.

      Leveraging our Benchmarking expertise, we deliver reliable data that supports informed decision-making and ensures regulatory compliance.

      Tax controversy and dispute resolution are crucial for businesses to effectively manage and resolve complex tax issues. We help safeguard against potential challenges and tax audits, ensuring compliance and minimising financial risks. 

      Our team of recognised experts has played a key role in Denmark's most significant tax cases, and consist of 360 advisors and former key figures from the Danish tax authorities and leading law firms.

      Pillar 2 & (Public) Country-by-Country Reporting involves assisting businesses in meeting global transparency requirements by accurately reporting transfer pricing data and financial information across different jurisdictions. We help navigate Pillar 2 and CbC reporting complexities, ensuring transparency and adherence to global tax regulations.

      Tax valuation services covers valuations of transactions and assets, ensuring alignment with market standards and regulatory requirements. Our services offer accurate tax valuations, supporting strategic decision-making and compliance, while highlighting opportunities in asset transfers.

      Operational Transfer Pricing (OTP) focuses on the practical implementation and management of transfer pricing policies, ensuring that day-to-day operations comply with established transfer pricing strategies and regulations. We streamline OTP by leveraging technology and clear processes, allowing you to focus on results while ensuring compliance and efficiency.



      Global transfer pricing rules and regulations

      Comprehensive information covering more than 100 countries and feedback on more than 200 questions.

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      Other relevant services

      We can assist you with advice on Danish and international corporate taxes ensuring compliance and optimisation of your tax position.

      Helping you protect against, prepare for, and resolve disputes with tax authorities.

      We rethink the role of the tax function, for the future.


      Explore our insights on Transfer Pricing

      Your one-stop destination for transfer pricing insights, events, and services.

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