Dispute resolution

Denmark Dispute Resolution Country Profile

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last update 12 April 2012

Competent Authority	Corporations and Individuals: Ministry of Taxation Customs and Tax Administration Centre for Large Enterprises International Corporate Tax Division Sluseholmen 8 B DK-2450 Copenhagen SV Tel: +45 7222 1818 Fax: +45 7222 1919
Organization	MAP & APA are both handled by: International Corporate Tax Division – a division within Centre for Large Enterprises. Head of International Corporate Tax Division: Mr. Troels Kjølby Nielsen
Scope of MAP & MAP APA	- Relief of double taxation for specific taxpayer. - Application and interpretation of articles in Double Tax Conventions (DTCs)
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 follows the OECD suggestions i.e. a preliminary meeting with the tax administration 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 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 for transfer pricing cases.
Government Website	http://www.skat.dk