CORIT managing director has been appointed expert in international tax dispute resolution

We are pleased and proud to announce that Jakob Bundgaard has accepted the appointment as Tribute Expert under the Tribute Foundation where he shall work with distinguished colleagues from all over the world to solve international tax disputes. See the announcement here

Tribute is an expertise center for international tax dispute resolution. Tribute aims to promote and support effective approaches for alternative, out-of-court resolution of international tax disputes. These approaches include the use of binding arbitration as well as non-binding supplementary forms of dispute resolution: conciliation, mediation, facilitation, or technical advice. Tribute has a global coverage, it is neutral and independent, and not for profit. Tribute is supported by leading international tax experts, professionals, academics, and government officials, from all parts of the world. Tribute offers a platform to all parties, in whatever capacity or of whatever background, that are involved with or take an interest in international tax dispute resolution. Just as much as disputes are a shared concern, effective dispute resolution is a shared concern, and a shared benefit, as well. Tribute offers a wide range of individually tailored services for all parties involved in processes of dispute resolution: authorities, courts, tribunals, arbitration institutes, or practitioners. These services include, for example, advice on the right choice of type of dispute resolution for a particular dispute, and its proper use; advice on the design of required legal instruments, like clauses, regulations, agreements, or procedures; assistance with facilities necessary for putting processes of dispute resolution in practice, in particular selection of arbitrators, mediators or facilitators, or technical advisers, and case administration; and, finally, practical training in how to effectively participate in resolution processes. You can read more about Tribute and its activities here

CORIT ranked as Tier 1 firm

In the 2020 edition of World Tax by International Tax Review, CORIT is ranked as a Tier 1 firm. CORIT is ranked Tier 1 as the only boutique firm and above all (but one) of the big full service law firms.  Being a newcomer in the market and a tax only firm for us this is an important milestone and significant achievement.

We are thankful and honored that to be recognized as one of the elite tax firms in Denmark and will allow ourselves to celebrate and be proud of this milestone.  

We would also like to express our gratitude to our clients and business partners. We promise to keep up the efforts and strive to improve.

The full ranking can be seen here

Discussion of the proposed CFC rules and the implementation of the final loss doctrine

The Danish Association on EU Tax Law has organized a membership meeting focusing on the new draft Bill (i) implementing new Danish CFC rules (ATAD), (ii) adjusting the definition of a permanent establishment (OECD BEPS), (iii) allowing deductions for final losses (ECJ case law) and (iv) amending the rules for discretionary assessments in transfer pricing cases.

Peter Koerver Schmidt and Michael Tell will both present and provide their thoughts in relation to the proposed CFC rules and the implementation of the final loss doctrine into Danish tax law. The meeting is Wednesday, October 9, 2019 at 16.00 – 18.00.

New article on the allocation of taxing right to payments for cloud computing-as-a-service

CORIT member Louise Fjord Kjærsgaard has published an article i World Tax Journal under the title “Allocation of the Taxing Right to Payments for Cloud Computing-as-a-Service”

In the article Louise analyses the options available to user jurisdictions for taxing the value generated by cloud computing service providers under current international tax rules. The focus is on mixed contracts, the distinction between business income and royalties and whether the provision of such services constitute a permanent establishment of the cloud computing service providers. Against this background, value creation and the fundamental principles of legal certainty, neutrality and the ability to pay tax are discussed.

The article is published in: World Tax Journal vol. 11 (2019) no. 3.