Denmark



World TP Reviews

Transfer pricing
CORIT Advisory

CORIT Advisory is a law firm that offers transfer pricing expertise to several clients. The firm assists its clients in aspects of transfer pricing formulation, documentation, implementation, and APA filing and negotiations. Katja Dyppel Weber is the senior transfer pricing lawyer at the firm. 

Recent activity involved formative transfer pricing advice relating to transaction delineation for the shipping industry before the Danish Tax Authorities. Arm’s length calculations were provided to a Nordic bank.

Deloitte

Deloitte has a sizeable team of transfer pricing professionals in Denmark, advising on a variety of transfer pricing matters, including business restructuring, documentation, transaction policy and MAPs/APAs. Asger Mosegaard Kelstrup is the partner in charge of Deloitte's transfer pricing team in Denmark. 

The team advised on highly complex financing structures inclusive of loans and guarantees for a renewable energy client. The team also prepared documentation for a royalties' deductibility case before the Supreme Court which is a rarity in Denmark.

KPMG

KPMG advises on all aspects of transfer pricing matters, with a full team of Denmark-based economists and lawyers capable of conducting all necessary analysis and advising on transfer pricing policy implementation. The firm also deals with transfer pricing disputes, as well as discussions with the authorities regarding MAPs and APAs. The transfer pricing department is led by a team of partners, including senior figures Henrik Lund and Simon Schaadt. 

Transfer pricing activity is confidential.

The transfer pricing team recently welcomed partner Peder Reuther. 

Plesner

Plesner is known as one of the leaders in tax litigation and the same is true of the firm’s transfer pricing team. It does not handle the creation or implementation of transfer pricing policies, instead using its knowledge of transfer pricing regulation to assist in negotiations with authorities and transfer pricing litigation. 

The team is handled a transfer pricing dispute with respect to cross-border purchases of goods from production companies in Thailand and Indonesia culminating in victory for ECCO. A landmark case with respect to the fundamental principles of valuing IP rights was also undertaken.