New article by Karl Berlin – The U.N.’s New Article 8 and the Taxation of International Shipping

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.

 

Event – The CORIT Transfer Pricing Lectures focusing on the Ørsted Arbitration Case

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.

If you have any questions, please feel free to contact us at event@corit.dk.

Event – M&A Seminar

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 event@corit.dk.

New article by Peter Koerver Schmidt, Kim Lundgaard Hansen and Casper Guldhammer Jensen – Taxation of royalties for the use of, and gains from the sale of, intellectual property/intangibles (Danish branch report)

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

New Contribution by Louise Blichfeldt Fjord and Peter Koerver Schmidt – The Impact of Artificial Intelligence on Tax Law.

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.

Link to the book

New article by Katja Dyppel Weber – Status over American Depositary Receipts (ADR) i en dansk skattemæssig kontekst

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.

Read the full article here.

 

New article by Jakob Bundgaard – Varsler et kombineret Skatte- og vækstministerium nye tider? Fromme håb og forslag til den nye regering

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.

Read the full article here.