Category: News

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.  

Read the article here

In light of the draft bill on CO2 transport by pipelines in Denmark, Katja Dyppel Weber has reflected on some of the tax implications the proposal gives rise to.

Read the English version here and the Danish version here.

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.

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.

In a newly published article in Tax Notes International, our managing director Jakob Bundgaard introduces a concept of private sector involvement in tax policy as a distinct professional services discipline in which private sector tax professionals can play an important role in the development of tax policy. At CORIT Advisory we are increasingly being engaged in international tax policy assignments.

Multinational enterprises of a certain caliber are being increasingly exposed to the challenges of international taxation, while policymakers (up to heads of state) and the public at large are paying ever greater attention to tax issues. This calls for a strategic approach to taxation, including
considering whether the private sector should engage in tax policy issues.

Bundgaard argues that we are witnessing a global trend of significantly increasing private sector engagement in tax policy issues — maybe in response to the increased public attention and interest in the topic. MNEs are strategically engaging in the field, aiming to prepare for the flow of new tax policy initiatives and to make themselves heard. They are eager to provide practical input to the design of new initiatives or to argue for improved framework conditions through constructive dialogue.

In this article the private sector tax engagement phenomenon is described and explained to uncover the contours of what is arguably an actual professional services discipline: private sector engagement in tax policy issues.

Please find the article below.