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
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,