In the January 2026 edition of Tax Notes International, our colleagues Andrea Højgaard Jørgensen, Katja Dyppel Weber, and Louise Blichfeldt Fjord, examine the ambiguity surrounding the concept of lost profit potential in transfer pricing, particularly in the context of business restructurings.
Louise Blichfeldt Fjord Promoted to Partner at CORIT Advisory
The CORIT Point of View 2025
We’re thrilled to wrap up an inspiring year by sharing our latest insights, publications, and highlights from the CORIT Team. This edition reflects the ideas, trends, and activities that shaped 2025—and what’s next on the horizon.
We hope you will enjoy it!
New Job Position – Student Assistant
New article by Karl Berlin – Cross-Border Loss Relief in Permanent Establishments: Lessons From Bevola.
In this article in Tax Notes International, Karl Berlin discusses how the treatment of losses incurred in foreign permanent establishments remains a contentious issue, creating a real risk of double non-deduction.
Read the full article here: https://lnkd.in/d97R-jn8
New article by Karl Berlin, Jakob Bundgaard and Katja Dyppel Weber – Skatteregler kan underminere et nyt udbud af havvindmøller
Denmark’s latest offshore wind auction introduces a two-sided CfD model and a 20-year support period, designed to provide the stable returns needed to attract investment in green infrastructure. This is a significant step forward for the energy transition.
However, as shown in a chronicle by Karl Berlin, Jakob Bundgaard, and Katja Dyppel Weber published in Berlingske today, a recent binding ruling from the Danish Tax Council may expose companies receiving the CfDs to ongoing taxation of unrealised market value changes, creating volatility and liquidity challenges that directly counteract the stability CfDs are meant to deliver.
We believe tax policy should support, not hinder, the green transition. Extending rules intended for financial derivatives to green energy contracts risks deterring investment and repeating past auction failures. Policymakers must clarify the tax treatment of CfDs to ensure Denmark’s climate ambitions remain credible and attractive to investors.
New article by Katja Dyppel Weber, Louise Blichfeldt Fjord and Karl Berlin – A Transfer Pricing Perspective on the Green Transition.
The green transition is transforming global energy markets, yet when it comes to transfer pricing for large-scale renewable projects, there is still no clear global best practice. This creates complexity for businesses and tax administrations alike.
In a Tax Notes International Special Report, our colleagues Karl Berlin, Katja Dyppel Weber and Louise Blichfeldt Fjord examine the transfer pricing challenges across the different phases of renewable generation projects. The OECD’s classic FAR analysis remains the cornerstone, but it must be applied with a clear understanding of the industry’s unique characteristics: high capital intensity, long lead times, phases that differ in functional intensity, assets as the primary value driver, and location factors such as physical conditions and access to state aid.
Our aim is to contribute to shaping best practice in this emerging field and to promote a balanced, level-headed approach that respects these fundamentals.
Read the full article here: https://lnkd.in/dHsykHey
New articale by Jakob Bundgaard – Muligheder for at isolere kapitalafkast i personselskaber via kapitalklasser?
In this article Jakob Bundgaard comments on a recent ruling, according to which tracking shares can be applied in partnerships while being fully recognized for tax law purposes.
Read the full article here
New article by Jakob Bundgaard – Alle gode gange tre – Om vanskelighederne ved at undslippe den generelle omgåelsesklausul
In this article Jakob Bundgaard reflects on a recent ruling which concerns the application of the Principal Purpose test.
Read the full article here
CORIT Advisory proudly announces its recognition in the World Tax 2026 rankings
The firm has secured Top Tier rankings in both Corporate Tax and Transfer Pricing, affirming its position as a leading force in the Danish tax advisory landscape.
“These rankings reflect the depth of our technical expertise and our ability to deliver strategic, tailored solutions across a wide range of tax disciplines – from M&A, international structuring and transfer pricing to tax controversy,” says Jakob Bundgaard, Managing Director at CORIT Advisory.
In addition to the firm’s top-tier rankings, all CORIT partners have been individually recognised as ‘Highly Regarded’, the highest distinction awarded to individuals in the guide. We are also proud to share that our youngest associate partner has been named a ‘Rising Star’, underscoring the strength and promise of our next generation of tax leaders.
Clients of CORIT Advisory echo this sentiment, highlighting the firm’s impact and precision:
“CORIT is comprised of technically excellent people who also know how to deliver top quality services tailored for the individual client company. The work CORIT performs is always in the absolute top of the range.”
The ITR (International Tax Review) World Tax guide is the most comprehensive ranking of tax practitioners globally, covering over 80 jurisdictions. This recognition underscores CORIT Advisory’s commitment to excellence, innovation, and client satisfaction in an increasingly complex tax environment.