Part of a comparative survey dealing with the particular constraints and opportunities connected with the relationship between transfer pricing policy and tax and business planning from both a domestic and a treaty law perspective. This article describes the Danish transfer pricing rules and the actions taken by the tax authorities with regard to controlled transactions with companies located in tax havens or preferential tax regimes, including profit-shifting through related companies, burden of proof, information retrieval, controlled foreign company rules, relocation of assets and activitites to tax havens or jurisdictions with preferential tax regimes, and reaction of tax authorities and legislature.