Dear reader,
We are pleased to present this year’s issue of the CORIT Point of View.
Enjoy!
New Article by Karl Berlin & Daniel Rath – Offshore Support Vessels Navigate Tonnage Tax and Pillar 2 Waters
In this article Karl Berlin and Daniel Rath go through the inconsistencies of how offshore support vessels such as AHTS vessels, PSVs and platform supply vessels are treated under various European tonnage tax regimes and the proposed treatment under the OECD Pillar 2 rules, and the uncertainties this creates.
Find a preview below or read the full Tax Notes article here.
New Article by Jakob Bundgaard – Armslængdestandardens betydning ved den EU-retlige misbrugsdoktrin– EU domstolens dom i sag C-585/22 X BV.
In this recent article Jakob Bundgaard addresses the role of the arm’s length principle in the EU doctrine of abuse based on the most recent case law from the European Court of Justice.
Read the article here: https://www.karnovgroup.dk/artikler/taxo-08-2024-afsagt
New Article by Jakob Bundgaard – Armslængdedestandardens betydning ved den EU-retlige misbrugsdoktrin – EU-domstolens dom i sag C-585/22 X BV
In this recent article Jakob Bundgaard addresses the role of the arm’s length principle in the EU doctrine of abuse based on the most recent case law from the European Court of Justice.
Read the article here: Taxo 08-2024 Afsagt
New Article by Daniel Rath & Karl Berlin – Navigation af specialfartøjer i farvandet mellem tonnageskat og Søjle 2
In this recent article Karl Berlin and Daniel Rath describe the challenges the Pillar 2 rules will create for e.g. wind installation vessels under tonnage tax.
Announcement – Bjørn Sibbern new CEO of Six Group
CORIT Advisory is proud to announce that our chairman of the Board of Directors and shareholder, as of 1. Jan. 2025 is appointed as the next CEO of the Six Group. The Six Group is a Swiss based global provider of financial services and information though technology and owns stock exchanges in Switzerland and Spain. Bjørn will continue as chairman of the Board of Directors at CORIT. We congratulate Bjørn on this great achievement and sincerely appreciate our ability to attract such accomplished and talented individuals from the global elite within the financial industry.
Read the announcement here: https://www.six-group.com/en/newsroom/media-releases/2024/20241128-new-ceo-six.html
New Article by Jakob Bundgaard – The 5 W’s of Successful Private Sector Engagement In Tax Policy Issues
New Article by Jakob Bundgaard – Lempelse af udbyttebeskatningen – en rose med virkelig spidse torne
In this recent article Jakob Bundgaard criticizes the introduction of the term beneficial ownership into domestic Danish tax law in the context of a pending Bill.
Read the article here: Afsagt Taxo 07-2024.pdf
New Article with Jakob Bundgaard and Karl Berlin – Skat kan fremme investeringer i grønne løsninger
New Report from the Danish Tax Law Council – Crypto-asset Taxation
In a brand-new report, the Danish Tax Law Council analyzes the current Danish rules for taxation of crypto-assets and discusses various options for improving the rules. The report also contains recommendations for new legislation in the area, which will ensure that investors have access to offset losses against gains on other crypto-assets and ensure that additional losses can be carried forward for deduction in the following income year’s gains on financial crypto-assets.
For the sake of simplification, a mark-to-market method is suggested for calculating gains and losses. To mitigate the potential liquidity burden of such a method, the Council suggests that the new rules are accompanied by a provision that allows so-called carry-back as well as a special provision to deal with sudden price falls that occur immediately after the end of the income year.
CORIT Advisory Partner Niels Winther-Sørensen is Chairman of the Tax Law Council and CORIT’s Academic Advisor Peter Koerver Schmidt is a member of the Council.
The press release and the report can be found here:
Ny rapport fra Skattelovrådet: Kryptoaktiver bør fremover lagerbeskattes | Skatteministeriet
