Author: Michelle

In this article Jakob Bundgaard reflects on a recent ruling which concerns the application of the Principal Purpose test.

Read the full article here

We’re proud to represent CORIT Advisory at the 77th International Fiscal Association Congress in Lisbon, 5–9 October 2025.

We look forward to engaging with peers and contributing to the global tax dialogue.

Will you be attending? Let’s connect on LinkedIn

In a recent article published in Tax Notes, Karl Berlin and Louise Blichfeldt Fjord explore the circumstances under which offshore activities, particularly those related to the construction and servicing of offshore energy assets, may give rise to a Permanent Establishment under the OECD and UN Model Tax Treaties. The article also examines select offshore-specific provisions, such as those found in the Double Tax Treaty between Denmark and the Netherlands.

Read the full article here

Anthology Contribution:
Louise Blichfeldt Fjord and Peter Koerver Schmidt, have contributed to the anthology “Denmark in Taxation and Inequalities,” edited by Rita de la Feria, published by IBFD Publishing (2025), (pp. 439-458.)

The theme of the book is described as follows:
“Everyone wants fair taxation, but what do we mean by it? What impact can taxation have on inequalities? To what extent should the tax system be used to redress them? And do we (truly) want it to do so? Based on extensive new tax law data, and informed by multidisciplinary insights, this book offers answers to what are arguably some of the most challenging questions of our times.”

Buy the book here

In this recent article Jakob Bundgaard comments on a recent ECJ decision interpreting the anti-abuse provision in the parent-/subsidiary directive and further reflects on the broader implications on the abuse doctrine.

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In this recent article Jakob Bundgaard and Karl Berlin described how the tax system could be used to support the build out of renewable energy in light of the new 3GW tender for offshore wind in Denmark.

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Our colleague Katja Dyppel Weber comments on a recent tax ruling on the Danish tax treatment of a Power Purchase Agreement. The tax ruling concerns a principal question of whether a fixed priced agreement with variable/floating volume can be considered a financial contract for tax purposes.

Read the full article here

In this recent article Karl Berlin describes the effect of the Pillar 2 rules on the sale of vessels, discussing a possible conflation of the notion of control with legal ownership, and the possible EU State aid dimension of how the Pillar 2 rules impact EU tonnage tax regimes.

Here’s the link to the live article in Tax Notes International: https://taxnotes.co/3YRqM1E