In a new article about SAFE, Niels has analyzed how a SAFE and similar financial instruments should be qualified for tax purposes in Danish tax law. Niels analyzes the Danish Tax Council’s (Skatterådets) latest decisions on this and is critical of certain parts of the Tax Council’s practice. Regardless of the criticism of the Tax Council’s decisions, the conclusion is clear: If you want to spread the use of the SAFE in Denmark, a change to the Danish tax legislation is necessary.
In the latest edition of Taxo Jakob Bundgaard considers the current global tax policy landscape and namely whether the past decades of coordinating efforts within in tax policy will be affected by the current geo-political tendencies and eventually lead to a more hostile environment between nations in terms of tax measures.
We are pleased being trusted to act as tax advisors to Blue Phoenix Group owned by InfraVia Capital Partners and Daiwa International Capital Partners in the acquisition of RGS Nordic in Denmark. We congratulate all partners on the deal!
Link: https://lnkd.in/emrDnqeb
Our Academic Advisor Peter Koerver Schmidt has recently been portrayed in the Magazine TAXO. Based on his legal research, Peter addresses issues such as corporate tax planning, responsible tax, international developments, tax complexity, and the increasing digitalization of the economy as well as the tax administration.
Access to the full interview can be found through this link:
https://www.karnovgroup.dk/artikler/taxo-03-2034-profil
The delineation of royalties in international tax law remains a hot topic. In this article Jakob Bundgaard comments on the recent Indian Hyatt case on the topic.
Read the article here
In a recent article in SR-Skat (SR.2024.69), Daniel Rath has commented on the R&D tax rules, as he provides some comments on the recent developments, the criteria of the rules, and the topic of documentation.
The article is available here
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
