Our colleague Katja Dyppel Weber comments on a recent tax ruling on the Danish tax treatment of a Power Purchase Agreement. The tax ruling concerns a principal question of whether a fixed priced agreement with variable/floating volume can be considered a financial contract for tax purposes.
Read the full article here
New Article by Karl Berlin – Pillar 2 Makes Waves for Vessel Sales and Shipping Income
In this recent article Karl Berlin describes the effect of the Pillar 2 rules on the sale of vessels, discussing a possible conflation of the notion of control with legal ownership, and the possible EU State aid dimension of how the Pillar 2 rules impact EU tonnage tax regimes.
Here’s the link to the live article in Tax Notes International: https://taxnotes.co/3YRqM1E
New Article by Jakob Bundgaard – Kulturbidraget anset som en handelshindring, og Danmark kan forvente “remedial action”
The Danish Cultural Contribution is now rightfully concluded by the United States Trade Representative to be a tax with extraterritorial effect that disproportionately affect US corporations. In this article Jakob Bundgaard considers the possible remedial actions which the US may bring into force with potential wide implication for many businesses.
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New Article by Jakob Bundgaard, Karl Berlin and Daniel Rath – The EU’s Net-Zero Act, Taxation, and Carbon Storage Market
In this recent article Jakob Bundgaard, Karl Berlin and Daniel Rath Rath provide a first take on the legal and tax consequences of the development of a future market for carbon capture and storage (CCS) with specific emphasis on the EU in light of the Net-Zero Industry Act (Regulation (EU) 2024/1735).
Read a preview below or find the full article here
New article by Jakob Bundgaard – Status på beskatningen af kapitalfonde 2025
In this article Jakob Bundgaard reflects on the developments with respect to taxation of the private equity industry over the course of the past some 15 years. It concluded, that the sector has played and still play a significant role in the tax policy and case law developments.
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New Article by Karl Berlin – Taxation of Demurrage and Detention Damages
In this recent article Karl Berlin discusses the tax treatment of detention and demurrage charges in shipping under double tax treaties and the Pillar 2 rules.
Find a preview below or read the full Tax Notes article here
A Tribute to the Successful Nordic Business Titans
CORIT Point Of View 2024
New Article by Karl Berlin & Daniel Rath – Offshore Support Vessels Navigate Tonnage Tax and Pillar 2 Waters
In this article Karl Berlin and Daniel Rath go through the inconsistencies of how offshore support vessels such as AHTS vessels, PSVs and platform supply vessels are treated under various European tonnage tax regimes and the proposed treatment under the OECD Pillar 2 rules, and the uncertainties this creates.
Find a preview below or read the full Tax Notes article here.
New Article by Jakob Bundgaard – Armslængdestandardens betydning ved den EU-retlige misbrugsdoktrin– EU domstolens dom i sag C-585/22 X BV.
In this recent article Jakob Bundgaard addresses the role of the arm’s length principle in the EU doctrine of abuse based on the most recent case law from the European Court of Justice.
Read the article here: https://www.karnovgroup.dk/artikler/taxo-08-2024-afsagt
