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Notice On The Auditor's Statement In Certain Cases Of Transfer Pricing

Original Language Title: Bekendtgørelse om revisorerklæring i visse sager om transfer pricing

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Table of Contents
Appendix 1

Completion of the auditor declaration in certain cases of transfer pricing

In accordance with section 3 B (1), 8, in the tax control law, cf. Law Order no. 819 of 27. June 2011, as amended by law no. 591 of 18. June 2012 shall be determined :

§ 1. When the conditions of section 3 B (b) of the tax control are laid down. 8 is fulfilled, SKAT may instrumentation a company to submit a statement from an auditor approved under the auditor bill, about the undertaking ' s documentation.

Paragraph 2. The company ' s documentation must show how the pricing and conditions for intra-group transactions are determined and must be able to form the basis for assessing whether prices and conditions are set in accordance with the crossings principle. The undertaking ' s documentation must be prepared in accordance with :

1) the section 2 of the body of the body

2) Tax Control Act, section 3 B,

3) Notice no. 42 of 24. January 2006 on the documentation of the price fixing of the operations checked and

4) OECD's Transfer Pricing Guidelines.

§ 2. Accountant must be in accordance with section 1 (2). 1, make a statement as to whether the auditor at the work carried out has been given rise to the conclusion that the transfer pricing documentation submitted to SKAT does not give a true image of the undertaking ' s undertaking ; the fixing of prices and conditions for the group internal transactions in accordance with section 1 (1). 2.

§ 3. A template for the declaration as an auditor can be set out in Appendix 1 to this notice.

Paragraph 2. The declaration shall be made in accordance with the provisions of the Declaration of Declarations relating to other declarations of security.

§ 4. The auditing declaration may be prepared in Danish, Norwegian, Swedish or English.

§ 5. The auditing declaration must be submitted to SKAT within 90 days of date of the date on the date of the date.

§ 6. The announcement shall enter into force on 1. March, 2013.

SKAT, the 8. February 2013

Jesper Rønnow Simonsen

/ Lisbeth Rasmussen

Appendix 1

Declaration of the independent auditor on the company ' s transfer pricing documentation

(see the statement on the auditor declaration in certain cases of transfer pricing,

Comcombe :
CVR no. :
Company name :
Company address :

To Management
(Identification of the TP documentation that is subject to the auditor ' s declaration and the information on the use of the conceptual framework, cf. Section 1 (1) of the notice. 2.)
Accountor responsibility and work carried out
Our responsibilities are, on the basis of our work, of expressing a conclusion on the abovementioned company's TP documentation (following a description of the work carried out).
Reservations
Conclusion of Reserved / Cancer Conclusion / Missing Conclusion
Conclusion
Conclusion with Reserve/Cancer Conclusions / Missing Conclusion
Supplementary information about TP documentation
Additional information on the work carried out
Date of the auditor's declaration :
Audit company name :
Auditor's signature :
The name and title of the audit :