Denmark Tax Agency Clarifies Transfer Pricing Rules for Valuation of Intangible Assets in Intra-Group Transfers

The Danish Customs and Tax Administration Dec. 10 posted National Tax Court Decision No. SKM2025.704.LSR, clarifying transfer pricing rules for the valuation of intangible assets in intra-group transfers. The taxpayer, a group subsidiary, transferred intellectual property (IP) to a new group company and continued providing routine sales and marketing services concerning the IP. The taxpayer prepared transfer pricing valuation reports using the discounted cash flow (DCF) method to calculate the IP’s value. The Tax Agency determined the transfer wasn’t at arm’s length. On appeal, the National Tax Court found that: 1) the taxpayer overestimated the value of routine functions by ...