Dispute resolution

Denmark Dispute Resolution Country Profile

 

 

 

last update 27 June 2014

 

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

Transfer pricing (articles 9 and 7):
Ministry of Taxation
Head of Office
Mr. Troels Kjølby Nielsen
Danish Customs and Tax Administration (DCTA)
Large Companies — Competent Authority
Sluseholmen 8 B
DK-2450 Copenhagen SV

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

Organization

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

None.

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

None

Tax collection / penalty / interest

Normal principles apply.

Other dispute resolution mechanisms

The EU Arbitration Convention

Government Website

http://www.skat.dk