Category: News

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.

 

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.

We are pleased to welcome Sune Hvelplund as Senior Director at CORIT Advisory.

Sune brings more than 18 years of experience in international tax and transfer pricing, with expertise spanning strategic advisory, compliance, and complex dispute resolution. He has extensive experience in transfer pricing controversy matters.

Prior to joining CORIT Advisory, Sune was a Director within International Tax and Transaction Services – Transfer Pricing and has been working across Denmark and Switzerland. His arrival further strengthens our transfer pricing practice at a time when demand for high‑quality cross‑border tax advice continues to grow.

Welcome to the team, Sune — we are delighted to have you on board!

The agreement and implementation of the EU Anti-Tax Avoidance Directive gave rise to several legal issues. Some of those issues are addressed in a recent decision of the European Court of Justice concerning the Belgian implementation of the directive’s CFC rules.

In this article, Jakob Bundgaard identifies relevant takeaways from the decision with respect to the purpose of the directive, the interaction between general and specific anti-abuse rules, as well as the nature of the directive as a minimum directive.

Read the full article here.

On the cover of this week’s Tax Notes International: A Narrower Lens on Source Taxation at Sea.

The OECD’s November 2025 update to the Model Tax Convention introduces a new, optional time-based permanent establishment test for offshore activities connected with the exploration for and exploitation of natural resources.

In this article, Karl Berlin explores the update and unpacks how the new offshore provision narrows its scope to finite natural resources, excludes renewable energy activities, and draws a line between core activities and auxiliary vessel operations. The article also shows why treaty drafting choices matter: the presence or absence of explicit carve‑outs for auxiliary activities drives materially different tax outcomes.

Read the full article in Tax Notes International here

We are proud to welcome our newest team member Rasmus Christian Johansen in the role of Director at CORIT Advisory.

Rasmus is an experienced transfer pricing specialist with a strong blend of strategic advisory skills and deep technical expertise. His arrival comes at a time where demand for high‑quality transfer pricing advice continues to grow, and the expansion of our TP practice is an important priority for CORIT.

Bringing Rasmus on board is therefore a natural and valuable next step as we strengthen our capabilities and continue to support clients with increasingly complex cross‑border tax challenges.

We are excited to have him join the team — Welcome, Rasmus!

In newly published article, Jakob Bundgaard comments on recent Danish case law from the Eastern High Court regarding the classical transfer pricing topic of the conversion from distributor to commissionaire. Despite being a well-known topic, clear precedents were previously absent. In this light, the ruling provides some clarity for future cases.

You can access the article here.

Our managing director, Jakob Bundgaard, will author his own permanent column in the Danish tax periodical Taxo, published by the legal publishing house Karnov Group. The articles will be published in a new format carrying his name, “Bundgaards perspektiv,” following his position as the most productive and most widely read contributor since the launch of the journal more than six years ago.

The first article in this new format concerns the tax law definition of convertible bonds and the importance of company formalities, such as timely registrations, in this regard. You can access the article here.