Recent Danish tax decisions challenge established assumptions about ADRs.
Three rulings from the Danish National Tax Tribunal revisit a fundamental question: can holders of American Depositary Receipts (ADRs) be regarded as shareholders of the underlying company for tax purposes?
The decisions appear to adopt a more restrictive approach than previous Danish tax practice, with potential implications for withholding tax refunds and cross-border investors.
In this article Katja Dyppel Weber explores the tax qualification of ADRs and the consequences of these developments.
The newly appointed dual Minister for Growth and taxation in the recently elected Danish Government gives rise to some hope for the future in terms of the combination of important societal agendas.
In this recent article Jakob Bundgaard reflects on this and presents some suggested focus areas within business taxation for the new Government.
The future role of the tax advisor in an AI defined era is top of mind throughout the industry. Our managing director presents some thoughts on this matter in this article here.
Mads Mammen Sørensen Associate, M.Sc. Business Administration and Commercial Law
E-mail: mms@corit.dk
Mads assists on a broad variety of tax matters including transfer pricing, corporate tax, incentive schemes, international tax.
Professional experience
2026 – Associate, CORIT Advisory 2025 – 2026 Student Assistant, CORIT Advisory 2023 – 2025 Student Assistant, Norlys Energy Trading A/S 2022 – 2023 Student Assistant, Department of Law, Aalborg University
Education
2026 Master of Business Administration and Commercial Law (cand.merc.jur), Aalborg University 2024 Bachelor of Business Administration and Commercial Law (HA (jur.)), Aalborg University
We are pleased to welcome Sune Hvelplund as Senior Director at CORIT Advisory.
Sune brings more than 18 years of experience in international tax and transfer pricing, with expertise spanning strategic advisory, compliance, and complex dispute resolution. He has extensive experience in transfer pricing controversy matters.
Prior to joining CORIT Advisory, Sune was a Director within International Tax and Transaction Services – Transfer Pricing and has been working across Denmark and Switzerland. His arrival further strengthens our transfer pricing practice at a time when demand for high‑quality cross‑border tax advice continues to grow.
Welcome to the team, Sune — we are delighted to have you on board!
Sune Hvelplund Senior Director, LL.M. Master of Laws
E-mail: suh@corit.dk Mobile: 51 58 26 04
Sune advises clients across the full spectrum of transfer pricing, from advisory and compliance to complex dispute resolution matters. With more than 18 years of experience in international corporate tax, he has deep expertise in transfer pricing controversy, including audits, negotiations with the Danish Tax Authorities, and MAP and APA proceedings.
Prior to joining CORIT Advisory, Sune was a Director within International Tax and Transaction Services – Transfer Pricing at EY, working across both Denmark and Switzerland. He is recognised for his ability to translate complex technical issues into clear and constructive advice, helping clients manage transfer pricing risk and navigate increasingly sophisticated cross‑border tax challenges.
2023 HD, Diploma in Financing, Copenhagen Business School 1998 LL.M – Master of Laws, Cornell Law School, NY, USA 1997 Master of Law, University of Copenhagen
The agreement and implementation of the EU Anti-Tax Avoidance Directive gave rise to several legal issues. Some of those issues are addressed in a recent decision of the European Court of Justice concerning the Belgian implementation of the directive’s CFC rules.
In this article, Jakob Bundgaard identifies relevant takeaways from the decision with respect to the purpose of the directive, the interaction between general and specific anti-abuse rules, as well as the nature of the directive as a minimum directive.
On the cover of this week’s Tax Notes International: A Narrower Lens on Source Taxation at Sea.
The OECD’s November 2025 update to the Model Tax Convention introduces a new, optional time-based permanent establishment test for offshore activities connected with the exploration for and exploitation of natural resources.
In this article, Karl Berlin explores the update and unpacks how the new offshore provision narrows its scope to finite natural resources, excludes renewable energy activities, and draws a line between core activities and auxiliary vessel operations. The article also shows why treaty drafting choices matter: the presence or absence of explicit carve‑outs for auxiliary activities drives materially different tax outcomes.
Read the full article in Tax Notes International here
We are proud to welcome our newest team member Rasmus Christian Johansen in the role of Director at CORIT Advisory.
Rasmus is an experienced transfer pricing specialist with a strong blend of strategic advisory skills and deep technical expertise. His arrival comes at a time where demand for high‑quality transfer pricing advice continues to grow, and the expansion of our TP practice is an important priority for CORIT.
Bringing Rasmus on board is therefore a natural and valuable next step as we strengthen our capabilities and continue to support clients with increasingly complex cross‑border tax challenges.
We are excited to have him join the team — Welcome, Rasmus!
