Category: News

Christian Plesner Rossing has joined CORIT Advisory as Technical Advisor on Transfer Pricing.

Christian has co-authored an article on transfer pricing knowledge management in multinational enterprises in International Transfer Pricing Journal, IBFD.

The article discusses transfer pricing knowledge management systems, a neglected topic in the international transfer pricing and tax risk management literature. The paper provides a guiding framework for multinationals seeking to work in a more organized manner with transfer pricing knowledge management, as well as specific ideas for identifying potential weaknesses in current knowledge management practices. These potential weaknesses are important to address, not least due to the recent publication of new OECD guidelines on transfer pricing documentation (BEPS Action 13), accentuating the need for systematic approaches to data and knowledge capture.

Read the article here.

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We are pleased to present the first issue of “The CORIT Point of View”.

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Peter Koerver Schmidt has published an article on additional protection rules’ implication for Danish CFC taxation.

The article analyses whether specific anti-avoidance provisions under Danish law are applicable when assessing the conditions for Danish taxation of controlled foreign companies (CFC-taxation) and when calculating the income to be attributed to the Danish parent company.

In this regard the decision made by the Danish Tax Assessment Council in SKM2014.577.SR is discussed.

Read the article here.

Peter Koerver Schmidt’s PhD thesis ”Dansk CFC-beskatning – i et internationalt og komparativt perspektiv” has been reviewed by Professor Jane Bolander in Nordic Tax Review.

The Professor finds the book “highly relevant with practical input”.

Read the review here.

Katja Dyppel Weber has published an article on the Danish tax treatment of tax losses from hydrocarbon activities in the North Sea.

The article explains the tax treatment of losses subject to the transitional rules in the Danish hydrocarbon tax act § 27 C. Further, the interplay between the hydrocarbon tax loss rules and the general tax law is discussed.

Further, the interplay between the hydrocarbon tax act and the general corporate income tax rules concerning tax losses is discussed.

Read the article here.​

Anders Nørgaard Laursen has published an article on the Nordea Bank Denmark Case (C-48/13).

The article analyzes the implications of the case and finds that reincorporation of previously deducted losses from a permanent establishment situated in another member state is allowed when certain requirements are fulfilled.

The case also questions whether the Danish international group tax rules are consistent with EU law.

Read the article here.

Peter Koerver Schmidt has published the article “Corporate Taxation and the International Challenge” discussing the Danish anti-avoidance rules.

The article concludes that the these anti-avoidance provisions often suffer from being quite complex, very broad in scope and open to criticism from an EU law perspective.

Read the article here.

Anders Nørgaard Laursen has written an article on exit taxation and the deferment balance analyzing whether interest expenses are deductible according to bill no. 170 of 26/2 2014. The author concludes that there is no legal authority to deduct interest expenses from a deferment balance.

Read the article here.

Anders Nørgaard Laursen has published an article on the most considerable regulatory changes in Danish international tax law from August 2013 to July 2014.

The article deals with exit taxation on companies, restricted withholding taxation, administrative guidelines on hiring-out of labour, taking up residence for individuals, and the calculation of personal income tax allowance relaxing taxation on foreign income.

Finally, the article deals with case C-48/13 Nordea Bank Danmark, and the 2014 update of the OECD model tax convention.

Read the article here.

Katja Dyppel Weber has published an article on Tax Treaty Treatment of Dividend Related Payments under Share Loan Agreements.

The article analyses the qualification and allocation challenges related to dividend payments under share loan agreements. The analysis includes a number of illustrating scenarios pointing out qualification and allocation conflicts for tax treaty purposes in cross-border situations.

Read the article here.