See the presentations here.
CORIT Managing director awarded prestigious tax prize
On Thursday the 27th of April our managing director Jakob Bundgaard was awarded the prestigious Karnov Tax Prize. The prize is awarded to a specialist who has contributed significantly to the development of the field of tax law. The prize was publicly revealed at an event taking place at the Danish National Museum, where the announcement and motivation was presented by Supreme Court Judge, Lars Apostoli and presented by the Danish Minister for Taxation, Karsten Lauritzen. We are humbled of this recognition which clearly reflects our relentless focus on technical skills and the interaction between academia and private practice. We are thankful and will work even harder to deserve the recognition.
Part 1 of the article Convertible Debt Instruments in International Law
This two-part article contains an in-depth analysis of a variety of convertible debt instruments from the perspective of international tax law. Part 1 covers optional convertible instruments, mandatory and reverse convertibles, contingent convertibles, warrants and option loans and provides an overview of domestic law in a number of countries.
Read the article here
NEW PRESENTATION ON THE PROPOSED COMMON (CONSOLIDATED) CORPORATE TAX BASE DIRECTIVE
See the presentation here
Inauguration of Anders Nørgaard Laursen as Professor
We hope to see as many as possible to the inauguration of Anders Nørgaard Laursen as professor.
Read more here.
Upcoming Seminar on the proposed C(C)CTB Directive
Seminar on the proposed Common (Consolidated) Corporate Tax Base Directive.
Read more here: Invitation – Understand the C(C)CTB Directive
New Paper on the Anti-Tax Avoidance Directive
Jakob Bundgaard and Peter Koerver Schmidt has authored an article on the ATA-Directive that emphasizes the differences to the originally proposed directive as well as the increased risk of double taxation.
Read here.
The CORIT Point of View
New Paper on the Qualification of Payment for Cloud Computing
Louise Fjord Kjærsgaard and Jolande Lærke Jørnsgård has authored an article regarding the qualification of payments for cloud computing according to the OECD Model Convention.
Read here.
New book on Hybrid Financial Instruments in International Tax Law
The book examines the tax issues affecting the use of hybrid financial instruments (HFIs).
Financial innovation allows companies and other entities that wish to raise capital to choose from a myriad of possible instruments that can be tailored to meet the specific business needs of the issuer and investor. However, such instruments put increasing pressure on a question that is fundamental to the tax and financial systems of a country – the distinction between debt and equity.
This book analyzes the treatment of HFIs – which lie somewhere along the debt-equity continuum, but where exactly depends on the terms of the instrument as well as on applicable laws – under both domestic law and tax treaties. Key jurisdictions, including the EU, some of its Member States, and the United States, are covered.
The book is available here.
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