Dispute resolution

Denmark Dispute Resolution Country Profile




last update: As from August 2016


Competent Authority 

Individuals and other double taxation issues:
Ministry of Taxation
Head of Office
Mr. Jesper Wang-Holm
Danish Customs and Tax Administration (DCTA)
Law Department
Østbanegade 123
DK-2100 Copenhagen Ø
or by e-mail to juraskat@skat.dk


Transfer pricing (articles 9 and 7):
Ministry of Taxation
Mr. Hans From
Danish Customs and Tax Administration (DCTA)
Large Companies — Competent Authority
Sluseholmen 8 B
DK-2450 Copenhagen SV
or by e-mail to store-selskaber-sikker-post@skat.dk


Tel: (both entities) +45 7222 1818
Fax: (both entities) +45 7222 1919


MAPs are handled by SKAT, Danish Customs and Tax Administration 

Scope of MAP & MAP APA

- Relief of double taxation for specific taxpayers.
- Application and interpretation of articles in Double Tax Conventions.

Domestic guidelines & administrative arrangements


Time for filing

MAP: DTC or domestic rules.
APA: No specific rules.

Form of request

No specific rules under Danish law.

MAP: No specific form is required. Written request is however expected.

APA: It is recommended that the taxpayer follow the OECD suggestions i.e. a preliminary meeting with DCTA, Large Companies — Competent Authority, after which the taxpayer will submit a detailed proposal.

Documentation requirement

No specific rules under Danish law.

In practice domestic transfer pricing documentation requirements cf. article 3 B in the Danish Tax Control Act is relevant especially in relation to APA cases.

User fees


Tax collection / penalty / interest

Normal principles apply.

Other dispute resolution mechanisms

The EU Arbitration Convention

Government Website



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