27/09/2020

Fine imposed for untimely transfer pricing documentation was reduced by half

hovedaktionærskat

Fine imposed for untimely transfer pricing documentation was reduced by half

The public prosecutor had claimed a fine of DKK 125,000 to a company for each income year that the company had not submitted its transfer pricing documentation to the Danish Tax Authorities on time. The district court found that the claimed fine each income year was not a proportionate fine. The court came to this conclusion despite the fact that it was specified in the drafting history of the law as being the legal position wanted by the law makers.

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