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.
Peter Koerver Schmidt has published an article on “The definition of tainted income under the Danish CFC-regime and the possibility of obtaining exemption – an analysis of two new administrative decisions”.
The article analyses two new administrative decisions concerning the Danish CFC rules applicable to companies. The first decision – issued by the Danish Tax Assessment Council – deals with the definition of tainted income under the CFC rules with respect to income originating from intellectual property rights. The second decision – issued by the Danish Tax Tribunal – concerns the conditions to be fulfilled in order to obtain exemption from the Danish CFC-rules. In this regard the article discusses the relatively controversial condition stating that the main part of the subsidiary’s income shall originate from business with clients in the country where the subsidiary is resident.
Read the article here.
Michael Tell participated at Queen Mary University of London, Tax Summer Programme, as speaker on advanced EU tax issues. He spoke on the highly debated topic exit taxation within the EU.
Read more about the conference here.
Peter Koerver Schmidt has participated in the tax conference ”Corporate Taxation and the International Challenge” held by Nordic Tax Research Council the 22th to 23th of May 2014.
Peter Koerver Schmidt was sent as the Danish legal national reporter. Further, he has held a lecture on Danish anti-avoidance rules in relation to hybrid entities. Finally, he has participated in a panel debate on the use of anti-avoidance rules in general.
Jakob Bundgaard publishes an article in top journal on debt-flavoured equity instruments in international tax law.
The article deals with how debt-flavoured equity instruments are treated in an international perspective. The article analyzes how preferred stocks are treated in Denmark, Germany and the US. Further, the article analyzes the treatment of preferred stocks according to double tax treaties and EU corporate tax law directives.
The article is available here.
Katja Joo Dyppel, senior associate at CORIT Advisory, has been included in the prestigious Talent100 award which was presented 24 April by Berlingske Nyhedsmagasin.
We are really proud of this acknowledgement of Katja and her accomplishments as an advisor and as an academic. At CORIT Advisory we also consider the inclusion as a recognition of our relentless focus on technical competences among our team members.
CORIT Advisory is looking for talented senior colleagues with an academic profile and a flair for business development.
Read more about the job advertisement here.