Africa

Danish High Court rejects discretionary tax assessment in groundbreaking transfer pricing case

Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, analyzes the High Court of Eastern Denmark’s March 28 ruling that dealt another harsh blow to the Danish Ministry of Taxation in the largest-ever transfer pricing case in Danish history regarding a USD 1.5 billion increase of taxable income for the oil business previously owned by A.P. Møller Maersk (now by Total Energies EP).

Denmark

Danish High Court rules on the application of EU Arbitration Convention and MAP in transfer pricing case

Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, discusses a recent transfer pricing ruling from the High Court of Eastern Denmark in a case on the application of the EU Arbitration Convention and mutual agreement procedures; this ruling is an indication that settling disputes by arbitration is an outcome that will become ever more important in the future of Danish tax law.