One of the trends of today’s fiscal environment is an increasing amount of tax controversy. Source and host countries are eager to attract more revenue, which is reflected in an increased aggressiveness from the tax authorities and legislators. This inevitably causes troubled waters for any business operating in several jurisdictions. CORIT Advisory can assist you in tax controversies with Danish and foreign tax authorities.
Our services within controversy comprise:
- – Presenting cases correctly and precise while identifying the best arguments available.
- – Assisting in dialogue and discussions with tax authorities.
- – Assisting in domestic and foreign cases, including MAP, negotiations, tax audits, complaints over discriminatory measures under EU law.
- – Engaging in litigation before the Danish Tax Tribunal and providing technical assistance in court cases.
At CORIT Advisory we believe that a proactive approach towards risk is beneficial in the long run. Consequently, we believe in the value of addressing different types of risk within the field of taxation and offer specific services in this respect, including the following:
- – Risk mitigation – analysis, opinions and defence files.
- – Improving tax communication to the non-tax world.
- – Development of tax policies and strategies.
- – Tax policy studies.
- – Handling of reputational issues.
The pricing of intergroup transactions is increasingly challenged by tax authorities and regulations while also the very nature of these transactions is continuously changing in the globalized world.
Our transfer pricing services mainly focus on:
- – Development of tailored transfer pricing strategies
- – Establishing the Group Master File
- – Establishing Local Files (both in Denmark and internationally)
- – Tax audit strategy and support
- – Annual update of the Group Master File and Local Files
- – Assistance in performing Country by Country reporting
- – Permanent establishments and place of effective management
- – Analysis on group structures – risks and input on improvements
At CORIT Advisory we work intensively with the tax consequences of the digitalization of the economy and the rise of new business models. We are experienced in determining the tax treatment of digitalized business models. Moreover, at CORIT Advisory we invest in gaining new knowledge and have launched several academic projects on this topic, including cloud computing, block chain, sharing economy, streaming services, treatment of data (valuation, nexus, profit allocation) etc.
Our services include:
- – Challenges that companies face in their daily business operations as a consequence of digitalization.
- – Determining the impact of intangibles in digital business models.
- – Analyzing the permanent establishments risks in light of international tendencies.
- – Handling the tax consequences of the sharing economy.
- – Analyzing transfer pricing aspects of digital business models.
- – Qualification of payment streams in digital business models.
In addition, we engage in the tax policy debate on the tax treatment of digitalized business models and are widely used lecturers and authors in this regard.
At CORIT Advisory we strongly believe that tax issues should be carefully addressed in connection with all transactions, including M&A. In addition, the interaction between tax law and corporate finance is one of the most important issues in tax systems today, as financial innovation and engineering pose important challenges to any tax system. At CORIT Advisory we assist clients in handling the risks associated with transactions, structuring and corporate financing decisions on a local and global scale. We strive to understand financial thinking and to understand the innovative processes underlying new financial structures or products and instruments in order to increase the value of our advice.
Our experience with corporate finance and financial instruments are significant and range from assisting in financial structures in M&A transactions and financing transactions to tax planning and arbitrage. Our clients include international financial institutions, investment banks, private equity funds and MNEs.
Our services within transactions, structuring and corporate finance comprise:
- – Cross border M&A and restructuring.
- – Development of robust investment structures.
- – Tax planning to achieve transaction goals.
- – Identification and handling of post-transaction challenges.
- – Analysis of financing structures, including withholding tax implications and interest deductibility.
- – Classification of financial instruments and products.
- – Hybrid finance.
- – Derivatives and hedging.
International business and globalization raise numerous tax issues that have to be addressed in order to reduce or eliminate the potential risks, which are invariably a part of today’s world. CORIT Advisory is able to assist your business in identifying and reducing such risks or to assist in obtaining a favourable tax position.
Our experiences are vast in working with international tax. We have provided services to many of the world’s MNEs and we prefer to serve clients with a clear international strategy. Our client base comprises both Danish and foreign MNEs.
Our services within corporate and international tax comprise:
- – Assistance within a wide range of tax matters ranging from day-to-day issues to large complex projects.
- – Advice regarding complex anti abuse legislation, EU law and tax treaty law.
- – Global tax risk assessments covering several countries and large amounts of data converted into overview, guidelines or concrete verifiable questions.
- – Advice regarding new business models.