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 article 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.
New article by Jakob Bundgaard – Svinger pendulet endnu en gang på skatteområdet?
In this article Jakob Bundgaard reflects on what seem to be a change in the perception of the tax area within companies. He argues that the pendulum may be swinging once again and provides some possible explanations for this as well as presents potential consequences from the change.
Read the full article here
CORIT Advisory at IFA 2025 – Lisbon
We’re proud to represent CORIT Advisory at the 77th International Fiscal Association Congress in Lisbon, 5–9 October 2025.
We look forward to engaging with peers and contributing to the global tax dialogue.
Will you be attending? Let’s connect on LinkedIn
New article by Karl Berlin & Louise Blichfeldt Fjord – The Sea as a Place of Business
In a recent article published in Tax Notes, Karl Berlin and Louise Blichfeldt Fjord explore the circumstances under which offshore activities, particularly those related to the construction and servicing of offshore energy assets, may give rise to a Permanent Establishment under the OECD and UN Model Tax Treaties. The article also examines select offshore-specific provisions, such as those found in the Double Tax Treaty between Denmark and the Netherlands.
Read the full article here
New article by Katja Dyppel Weber – Taxing Special Purpose Vehicles and Controlling Operational Risk
In this recent article in Tax Notes, Katja Dyppel Weber together with Arne Mollin Ottosen and Lenni Hangaard Jensen comment on the Danish tax tribunal’s ruling in a transfer pricing case dealing with, among other things, the allocation of income based on control over risks. The case is under appeal and is pending before the Danish Eastern High Court.
Read the full article here
New Contribution by Louise Blichfeldt Fjord and Peter Koerver Schmidt – Denmark in Taxation and Inequalities
Anthology Contribution:
Louise Blichfeldt Fjord and Peter Koerver Schmidt, have contributed to the anthology “Denmark in Taxation and Inequalities,” edited by Rita de la Feria, published by IBFD Publishing (2025), (pp. 439-458.)
The theme of the book is described as follows:
“Everyone wants fair taxation, but what do we mean by it? What impact can taxation have on inequalities? To what extent should the tax system be used to redress them? And do we (truly) want it to do so? Based on extensive new tax law data, and informed by multidisciplinary insights, this book offers answers to what are arguably some of the most challenging questions of our times.”
Buy the book here
