In this recent article Jakob Bundgaard comments on a recent ECJ decision interpreting the anti-abuse provision in the parent-/subsidiary directive and further reflects on the broader implications on the abuse doctrine.
Read the article here
In this recent article Jakob Bundgaard and Karl Berlin described how the tax system could be used to support the build out of renewable energy in light of the new 3GW tender for offshore wind in Denmark.
Read the article here
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
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
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.
Read the article here
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
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.
Read the article here
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