Can we help you?

Do you find yourself needing

1. Assistance in tax and transfer pricing audit, both strategically and operationally, actively supporting with preparation of documents for tax authorities?
2. Support in obtaining relief from double taxation through mutual agreement procedures using double tax treaties and/or the EU arbitration convention? We’ll prepare the application, support on the submission and help coordinating with the Competent Authorities.
3. Assistance in preparing and leading unilateral and bilateral Advance Pricing Arrangements (APA) procedures to obtain certainty on certain specific intercompany transactions for a pre-determined period of time?
4. Assistance with preparation of complaints to the Danish Tax Tribunal, presenting statement of facts, analysis and conclusions, representation/participation in meetings with case officers, as well as representation before the Tax Tribunal?
5. Value chain analysis for allocation of business profits or transfer pricing documentation.
6. Assistance in identifying and establishing simple day to day processes that can make a world of difference in terms of operationalising transfer pricing compliance with potential spill-over effects to e.g. VAT compliance?
7. Having to realign the transfer pricing setup after a restructuring, i.e. sale or close down of activities, mergers or spin-offs?
8. Support on post-acquisition integration, restructuring and legal entity rationalisations?
9. Help preparing transfer pricing documentation, both master files and local files for Danish and foreign entities?
10. An extra set of hands in your daily operations to tackle a busy period? We take on insourcing assignments.
11. To prepare database analysis for goods and services transactions to determine the arm’s length range?
12. A profit split analysis for situations where more parties contribute unique and valuable intangible assets or significant functions?
13. Support in valuation of business transfers, sale of tangible and intangible assets, preparation of defense files etc.?
14. A strong Tax Governance framework?
15. A penalty assessment for non-compliance with the mandatory submission requirement for transfer pricing documentation?
16. Support with communcation with the Danish Tax Authorities following a penalty for not submitting transfer pricing within the deadline or submitting inadequate transfer pricing documentation?
17. To prepare intercompany agreements for goods, services, software as a service, financial transactions, etc.?
18. To establish and implement sustainable operational methodologies for allocating of shared services costs to benefitting related parties?
19. An economic analysis of royalty rates used in license transactions, including preparation of internal CUP analysis or database analysis?
20. Assistance with Country-by-Country Reporting, both for the notification procedures, compilation of data, and submission for the reporting entity?
21. Help preparing qualifications and calculations under the interest deduction limitation rules?
22. A second opinon on complex technical issues, strategically important transactions, transactions with few facts available, etc. for management and/or for potential buyers?
23. Tax issues of establishing a shared service centers abroad?
24. Strategic advice on establishing new intercompany transactions or realigning existing intercompany transactions?
25. A risk assessment for management in connection with tax audits, relief from double taxation procedures, and litigation procedures?
26. To prepare DAC6 reporting? Including transactions related to cross-border business restructurings and transfers of IP, customer lists, inventory etc. to affiliates?
27. To prepare Danish corporate income tax returns?
28. To prepare interest rate analysis to establish the arm’s length pricing of current credit facilities, term loans, and more specialised loans?
29. An assessment of how potential restructurings, divestments, etc. will impact the recapture balance in international joint taxation?
30. A Danish permanent establishment assessments including assessment on Denmark’s Exclusive Economic Zone?
31. Assistance in determining the Danish CFC position, including detailed qualifications of income and cost streams?
32. Advice on the attribution of profits to permanent establishments in accordance with OECD’s authorised approach?
33. To establish a Nordic hub?
34. An assessment of the possibility of utilizing final tax losses abroad?
35. A guarantee fee analysis to establish the arm’s length value of financial or performance guarantees?
36. Building strong internal tax controls in your organisation and data management?
37. Implementing a system to timely identify and quantify tax risks across your organisation?
38. Considering how to address ESG for tax?
39. Struggling with understanding how of effectively outsource tax to a third party service provider, while maintaining control and oversight?
40. To evaluate how it affects the business model when executive management resides in multiple location?
41. Help establishing the Danish withholding tax position for foreign groups with Danish subsidiaries?
42. Transfer price indexing the valuation of towels in intergalactic space travel. Yes, it's a Douglas Adams joke. If you got to the end of this list, you are probably ripe for a bit of fun