AmCham Engages with SKAT on Transfer Pricing

On September 14, AmCham participated in a Transfer Pricing (TP) dialogue meeting hosted by SKAT (The Danish Customs and Tax Administration) at AC Hotel Bella Sky in Copenhagen. This was the second dialogue meeting arranged by SKAT, which offers  the private sector an opportunity to highlight issues that Danish and international companies experience when dealing with SKAT’s TP department.

Minister of Taxation Karsten Lauritzen kicked off the meeting by praising the Danish business community for their openness and transparency. He also noted that despite the sometimes negative rhetoric in Danish media, the partnership between SKAT and international companies is positive and built on diligence and trust.

Other speakers included: Hans From, Deputy Director (SKAT); Asger Kelstrup, Partner (Deloitte); Clive Baxter, Head of Tax Policy and Governance (Maersk Group); Klaus Oxholm, Partner (PwC) and Anders Oreby Hansen, Partner (Bech-Bruun). AmCham was represented by Johnny Bøgebjerg, Tax Director at KPMG, who participated in the panel debate ‘Future Tax Initiatives’. 

The main discussion points at the meeting included:

  • The overall working partnership between SKAT and international companies
  • Initiatives to hinder double taxation of international companies
  • The difficulty of setting a ‘right’ arm’s length principle price within a complex system
  • The lengthy case processing the tax audits and competent authority procedures 
  • How new technology and digitalization could help ease the case processing
  • The immense amount of documentation that SKAT requires for case processing
  • Rethinking alternatives the APA program – external mediators?

Since 2014, international companies indicate that they see an improved level of cooperation with SKAT. SKAT’s professional level is higher and their communication (also in English) is clearer, which helps ease the dialogue specifically for the international companies.

AmCham Denmark is part of SKAT’s advisory group. SKAT established the group in order to gather input from the business community. The group meets with SKAT regularly to discuss the working partnership and general case processing in order to maintain a well-functioning cooperation. SKAT will continue to work with the advisory group to ensure a consistent case processing. If you want to be updated on the advisory group’s work, please contact the AmCham secretariat at mail@amcham.dk or 33 932 932.

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