Denmark vs. Danish Production A/S, Feb 2018, Tax Tribunal, SKM2018.62.LSR

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The Danish Tax Tribunal found that the tax administration had been entitled to make a discretionary assessment, due to the lack of a comparability analysis in the company’s transfer pricing documentation.

The Tax Tribunal also found that the Danish company had correctly been chosen as tested party when applying the TNMM, although the foreign sales companies were the least complex. Information about the foreign sales companies was insufficient and a significant part of the income in the foreign sales companies related to sale of goods not purchased from the Danish production company.

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