New transfer pricing approach

On 27 October 2004, the Minister of Taxation published draft legislation that would tighten transfer pricing rules. The draft legislation is interesting in an EU context, as it may set the standard for a wave of transfer pricing changes in other EU Member States. Accordingly, in order to comply with the principle of freedom of establishment as set forth in Art. 43 of the EU Treaty, the Danish transfer pricing documentation requirements are expanded to include domestic transactions.