Denmark's new transfer pricing IP valuation guideline

Skat's (Denmark's tax authorities) have issued new guidelines on IP valuation entitled "Transfer Pricing, controlled transactions, valuation". Google's handy translation tool will translate the lengthy download in the link for interested readers. Deloitte's summary provides the once over:

"The new guidelines significantly change the generally accepted approaches to valuing individual intangible assets, as well as entire businesses, for Danish transfer pricing purposes. The guidelines focus on forward-looking valuation approaches, which are generally in line with the methodologies followed by most taxpayers. However, the documentation requirements included in the guidelines are broad and extensive and not well-defined. Accordingly, the guidelines should be considered in detail when contemplating IP or business reorganizations involving Danish groups or entities." Deloitte