Denmark has implemented Country-by-Country (CbC) Reporting as part of its compliance with the Base Erosion and Profit Shifting (BEPS) Action Plan 13, which was developed by the Organisation for Economic Co-operation and Development (OECD).

Multinational Enterprises (MNEs) with a consolidated group revenue of at least EUR 750 million in the previous fiscal year are required to file a CbC report in Denmark. The report should be in XML format and should contain information on the global allocation of income, taxes paid, and other indicators of economic activity among tax jurisdictions in which the MNE group operates.

The ultimate parent entity of the MNE group is responsible for filing the CbC report if it is resident in Denmark. If the ultimate parent entity is not resident in Denmark, the obligation to file the CbC report falls on the surrogate parent entity, if any, that is resident in Denmark.

The deadline for filing the CbC report in Denmark is within 12 months from the end of the fiscal year of the MNE group. For example, if the fiscal year of the MNE group ends on December 31, the CbC report must be filed by December 31 of the following year. Failure to file the CbC report or providing false or misleading information can result in penalties.

Denmark has implemented a penalty regime for non-compliance with CbC Reporting requirements. MNEs that fail to file the CbC report or provide incomplete or inaccurate information can be fined up to DKK 200,000 (approximately USD 32,000).

MNEs must file the CbC report in Denmark electronically through the Danish Business Authority’s website. The website provides a CbC Reporting portal that allows MNEs to upload their CbC report in XML format. The Danish Business Authority will send a confirmation of receipt once the report has been successfully submitted.

In addition to the CbC report, MNEs operating in Denmark may be required to prepare and file a Transfer Pricing Documentation (TPD) report. The TPD report should provide detailed information on the pricing of related party transactions within the MNE group.

In conclusion, Denmark has implemented CbC Reporting requirements as part of its compliance with the OECD’s BEPS Action Plan 13. MNEs with a consolidated group revenue of at least EUR 750 million in the previous fiscal year must file a CbC report in Denmark in XML format. The deadline for filing the CbC report is within 12 months from the end of the fiscal year of the MNE group. Failure to comply with CbC Reporting requirements can result in penalties, and MNEs must also prepare and file a Transfer Pricing Documentation report if required.