In this article, Jakob Bundgaard briefly reflects on the recent decision of the European Court of Justice in the NEO group case.
The case concerns the generally applicable anti-avoidance rules in the parent-/subsidiary directive but does provide some further perspective on the broader EU doctrine of abuse in cross-border structures and payment flows.
You can access the full article here.
CORIT Advisory has once again been awarded Tier 1 rankings in both Corporate Tax and Transfer Pricing by International Tax Review (ITR), maintaining its position among Denmark’s leading independent tax advisory firms.
The recognition reflects CORIT’s continued focus on providing technically strong, commercially relevant advice on complex Danish and international tax matters.
“We are very proud to retain our Tier 1 rankings in both Corporate Tax and Transfer Pricing. For us, the recognition is particularly meaningful because it reflects the work we do together with our clients on some of their most complex tax matters. Our ambition has always been to combine deep technical expertise with a practical understanding of the businesses we advise,” says Jakob Bundgaard, Managing Director at CORIT Advisory.
The individual rankings also recognise the strength of CORIT’s partner team. Three of the firm’s four partners have been recognised as ‘Highly Regarded’, the highest distinction awarded to individuals in the guide, while the firm’s youngest partner has been named a ‘Rising Star’.
The rankings come as CORIT continues to advise Danish and international clients across corporate tax, international taxation, transfer pricing, M&A, tax controversy and cross-border structuring.
The ITR World Tax guide ranks tax firms and practitioners across jurisdictions worldwide based on extensive market research and feedback from clients and peers.
For CORIT, retaining Tier 1 status in both Corporate Tax and Transfer Pricing is ultimately a reflection of the trust placed in the firm by its clients and the collective expertise of the entire team.
We are pleased to share that our partner, Karl Berlin, has published a new article in Tax Notes on the UN’s new Article 8 and the taxation of international shipping.
The updated Article 8 in the UN Model Tax Convention marks a notable development in international tax treaty policy. In the article, Karl analyses the rationale behind the new provision, its departure from the traditional treaty treatment of international shipping income, and the broader implications for the allocation of taxing rights between jurisdictions.
You can access the full article here.
CORIT Advisory is pleased to invite you to another session in our series The CORIT Transfer Pricing Lectures focusing on the Ørsted Arbitration Case.
This session offers a rare opportunity to hear directly from the people who have led one of Europe’s most significant transfer pricing controversies from audit through international dispute resolution.
Peter Lund Christiansen, Head of Tax at Ørsted, and Tina Hasselgren, Head of Transfer Pricing at Ørsted, will join us for what promises to be a unique and highly practical discussion of one of the most significant transfer pricing disputes ever pursued under the EU Arbitration Convention.
Register for the session here.
The Ørsted Arbitration Case
An Advisory Commission established under the EU Arbitration Convention has recently issued its final opinion in the first cases arising from what is widely regarded as Denmark’s largest transfer pricing audit.
The case concerns Ørsted’s offshore wind business and raises fundamental questions about how transfer pricing principles apply to innovative and highly integrated business models. While the dispute originated in the renewable energy sector, the issues extend far beyond offshore wind. They are equally relevant to businesses developing new value chains, digital platforms, and AI-enabled operating models where traditional concepts of value creation are increasingly being tested.
Drawing on more than a decade of experience from the case, Peter and Tina will share their perspectives on the technical issues, the dispute process itself, and the strategic choices made throughout the proceedings. Together, we will explore what the outcome may mean for transfer pricing practice, dispute prevention, and dispute resolution in the years ahead.
Arbejder du med M&A, investeringer eller selskabsret, men ikke nødvendigvis med skat til daglig?
På CORIT Advisorys morgenbriefing sætter vi fokus på aktuelle skatteforhold, der kan få væsentlig betydning i transaktionsprocessen. Vi deler praktiske erfaringer og den seneste udvikling.
Tilmeld dig her.
Ved spørgsmål kan vi kontaktes på [email protected].
Taxation of royalties for the use of, and gains from the sale of, intellectual property/intangibles (Danish branch report), The 78th Congress IFA Melbourne, Vol. 110 a, p. 521-552, 2026, Co-authors: Peter Koerver Schmidt, Kim Lundgaard Hansen and Casper Guldhammer Jensen
Read the full report here
Tax and the energy transition (Danish branch report), The 78th Congress IFA Melbourne, Vol. 110 b, p. 495-520, 2026, Co-authors: Nina Legaard Kristensen and Karl Berlin
Read the full article here
In his latest article, Jakob Bundgaard takes a closer look at recent legislative developments and discusses whether they could lead to a broader application of the Danish general anti-avoidance rule than originally intended.
Read the full article here
We are pleased to have contributed to the newly published IBFD book: The Impact of Artificial Intelligence on Tax Law. The publication explores how AI is transforming tax administrations and their interactions with taxpayers across jurisdictions worldwide, including key questions relating to transparency, governance, data protection, and taxpayer rights.
CORIT members Louise Blichfeldt Fjord and Peter Koerver Schmidt contributed the Danish chapter together with Siddesh Rao, providing insights into the Danish perspective on these important developments.
