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Transfer Pricing Agreement

Transfer Pricing Agreement Template for Denmark

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Transfer Pricing Agreement

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Document background
Transfer Pricing Agreements are essential documents for multinational enterprises operating in Denmark to establish and document their intercompany pricing arrangements. These agreements are particularly crucial given Denmark's strict transfer pricing documentation requirements and adherence to OECD Guidelines. A Transfer Pricing Agreement helps companies demonstrate compliance with the arm's length principle, as required by Danish tax authorities, while providing a framework for consistent application of transfer pricing policies. The agreement typically includes comprehensive details about pricing methodologies, documentation requirements, and compliance procedures, helping companies manage their transfer pricing risks and obligations under Danish law. It serves as a key document for both operational purposes and potential tax authority reviews.
Suggested Sections

1. Parties: Identification of the related entities entering into the agreement, including registration numbers and jurisdictions

2. Background: Context of the agreement, relationship between parties, and business rationale for transfer pricing arrangement

3. Definitions: Key terms used throughout the agreement, including technical transfer pricing terminology

4. Scope of Agreement: Description of transactions covered, products/services involved, and territorial scope

5. Transfer Pricing Methodology: Detailed explanation of chosen pricing method(s) and justification for selection

6. Pricing Terms and Calculations: Specific pricing formulas, margins, and calculation methods

7. Documentation Requirements: Obligations regarding maintenance of transfer pricing documentation, including Master File and Local File requirements

8. Compliance and Reporting: Procedures for ensuring compliance with Danish tax regulations and reporting obligations

9. Term and Termination: Duration of the agreement and conditions for termination

10. Representations and Warranties: Standard declarations regarding capacity, authority, and compliance

11. Dispute Resolution: Procedures for handling disputes, including competent authority procedures

12. Governing Law: Confirmation of Danish law as governing law and jurisdiction

Optional Sections

1. Critical Assumptions: Specific conditions under which the agreement operates, used when certain market or business conditions are crucial to the pricing method

2. Advance Pricing Agreement Integration: Required when the transfer pricing agreement needs to align with an existing or pending APA

3. Cost Sharing Provisions: Needed when parties share development costs or risks

4. Foreign Exchange Provisions: Required for cross-border transactions involving multiple currencies

5. Periodic Adjustment Mechanism: Used when regular price adjustments may be needed based on market conditions

6. Force Majeure: Optional provisions for extraordinary circumstances affecting pricing

7. Intellectual Property Rights: Required when IP transfers or licenses are part of the pricing arrangement

Suggested Schedules

1. Schedule A - Covered Transactions: Detailed list of all intercompany transactions covered by the agreement

2. Schedule B - Pricing Methodology Details: Detailed calculations, comparables, and specific pricing formulas

3. Schedule C - Documentation Requirements: Specific documentation templates and requirements for both parties

4. Schedule D - Functional Analysis: Detailed analysis of functions, assets, and risks of each party

5. Schedule E - Benchmark Analysis: Comparable company analysis and market data supporting the chosen methodology

6. Appendix 1 - Reporting Templates: Standard templates for periodic transfer pricing reports

7. Appendix 2 - Compliance Checklist: Checklist ensuring compliance with Danish transfer pricing requirements

8. Appendix 3 - Group Structure Chart: Organization chart showing relationship between parties

Authors

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Relevant legal definitions
Affiliated Entities
Arm's Length Principle
Associated Enterprise
Benchmarking Study
Comparable Uncontrolled Price
Competent Authority
Controlled Transaction
Cost Plus Method
Critical Assumptions
Danish Tax Authority
Documentation Requirements
Effective Date
Financial Year
Functional Analysis
Group
Intercompany Transaction
Local File
Master File
Net Profit Margin
OECD Guidelines
Operating Profit
Parent Company
Profit Level Indicator
Profit Split Method
Related Party
Resale Price Method
Tested Party
Transaction Net Margin Method
Transfer Pricing Adjustment
Transfer Pricing Documentation
Transfer Pricing Method
Uncontrolled Transaction
Working Capital Adjustment
Benchmark Range
Compliance Period
Contemporaneous Documentation
Covered Transactions
Dispute Resolution Procedure
Force Majeure Event
Intellectual Property Rights
Material Change
Operating Expenses
Pricing Period
Reference Market
Services
Tangible Property
Tax Assessment
Territory
Clauses
Interpretation
Definitions
Scope of Agreement
Transfer Pricing Methodology
Pricing Terms
Documentation Requirements
Compliance Obligations
Reporting Requirements
Record Keeping
Audit Rights
Confidentiality
Data Protection
Force Majeure
Representations and Warranties
Term and Duration
Termination
Dispute Resolution
Governing Law
Entire Agreement
Amendment
Assignment
Notices
Severability
Third Party Rights
Cooperation
Tax Adjustments
Currency Provisions
Price Review
Indemnification
Information Exchange
Non-Compliance Remedies
Change in Law
Cost Allocation
Implementation
Competent Authority Proceedings
Periodic Review
Intellectual Property
Business Restructuring
Mutual Agreement
Relevant Industries
Relevant Teams
Relevant Roles
Industries
Danish Tax Control Act (Skattekontrolloven) Section 3B: Primary legislation governing transfer pricing in Denmark, establishing the arm's length principle and defining related parties
Danish Tax Assessment Act (Ligningsloven) Section 2: Provides legal basis for transfer pricing adjustments and enforcement of arm's length principle
OECD Transfer Pricing Guidelines: International guidelines followed by Denmark for transfer pricing methodology and documentation requirements
Danish Transfer Pricing Documentation Executive Order: Specific requirements for transfer pricing documentation, including Master File and Local File requirements
Danish Tax Control Act Section 84: Penalties for non-compliance with transfer pricing documentation requirements
BEPS Action 13: Country-by-Country reporting requirements implemented in Danish law for multinational enterprises
Danish Administrative Tax Law (Skatteforvaltningsloven): Procedures for dispute resolution and appeals in transfer pricing cases
EU Joint Transfer Pricing Forum Guidelines: EU-specific guidance on transfer pricing that applies to Danish cross-border transactions within the EU
Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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