In a recent article in SR-Skat (SR.2024.69), Daniel Rath has commented on the R&D tax rules, as he provides some comments on the recent developments, the criteria of the rules, and the topic of documentation.
The article is available here
Increasingly, states are trying to obtain source taxation. One approach is to identify royalty payments – even where there are none. This situation arises when states argue that payments for services or goods partially comprise payments for the use of or the right to use IP rights – so-called embedded royalties. A recent Australian decision in the PepsiCo case may shed light on the issue. Jakob Bundgaard has authored an article covering the issue, the decision and its wider implications.
Read the article here
In his latest article, CORIT Academic Advisor Peter Koerver Scmidt deals with the European Commission’s recent proposal to establish a common framework for corporate taxation in the EU in order to achieve a more efficient internal market and reduce administrative costs for groups. The focus is on explaining and discussing essential elements of the proposal, including the scope and the calculation, consolidation, and allocation principles. Peter points out that the proposal (still) contains a number of shortcomings and ambiguities, but also a number of positive elements that could contribute to a better functioning corporate tax regime and bring a number of benefits to the groups covered.
What better way to start the year than by proudly announcing another addition to our growing team.
Maria brings with her some years of M&A experience from a leading law firm. At CORIT she will focus broadly on international corporate tax.
Maria Holck Wils
Associate, M.Sc. Business Administration and Commercial Law
E-mail: mhw@corit.dk
Mobile: +45 28 29 75 60
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Professional experience
2024 – Associate, CORIT Advisory P/S
2021 – 2024 Erhvervsjuridisk fuldmægtig, Bruun & Hjejle Advokatpartnerselskab
2019 – 2021 Student Assistant, Erhvervsstyrelsen
Education
2021 Master of Business Administration and Commercial Law, Copenhagen Business School, Frederiksberg
Based on a recent ruling, Jakob Bundgaard in a recent article considers the notion of a warrant in Danish tax law in light of the legal interaction between tax law and private law.
Read the full article here.
We are proud to announce our newest addition to the CORIT Team – René Lønne Arenfeldt.
René joins us with more than 10 years of experience with a broad range of topics within corporate tax taking on the role as Associate Partner. As part of our strategy of manifesting ourselves as a regional tax powerhouse René’s focus lies on developing new business areas and thereby strengthen our portfolio and service offering.
As a team we look very much forward to achieving new milestones that will contribute to our continuous expansion.
