Denmark

Corporate taxation

The corporate tax rate in Denmark is 22% in 2017.

Transfer pricing

The Tax Assessment Act, Section 2, contains the Danish arm’s length provision and in the explanatory memoranda (preparatory legislative work) there is a direct reference to the arm’s length principle contained and described in the OECD Transfer Pricing Guidelines (hereafter TPG). Hence, in Denmark the arm’s length provision is interpreted according to the arm’s length principle contained and described in the TPG.The Danish Tax Control Act, Section 3B, requires taxpayers to a) disclose information about transfer pricing in their tax returns and b) prepare and submit transfer pricing documentation on request and c) requires filing of CbC reports.

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Transfer Pricing Case Law

Case Name Description Date Court Keywords
Denmark vs. Swiss Re. February 2012, Supreme Court, SKM2012.92 This case concerned the Danish company, Swiss Re, Copenhagen Holding ApS, which was wholly owned by the US company, ERC Life Reinsurance Corporation.

In 1999 the group considered transferring the German subsidiary, ERC Frankona Reinsurance Holding GmbH, from the US parent company to the Danish company. The value of the German company was determined to be DKK 7.8 billion. The purchase price was to be settled by the Danish Company issuing shares with a market value of DKK 4.2 billion and debt with a market value of DKK 3.6 billion.
On 27 May 1999, the parent company and the Danish company considered to structure the debt as a subordinated, zero-coupon note. Compensation for the loan would be structured as a built-in capital gain in order to defer recognition of the compensation for the period 1 July 1999 to 30 June 2000. The Danish company would be unable to use a deduction in income year 1999. A built-in capital gain should be recognized in 2000 where payment of the first instalment would be made. If the compensation were structured as interest payments, the compensation should be recognized on an accrual basis. On 17 June 1999, a bank provided the Danish Company with information about market terms for a zero-coupon loan.
On 21 June 1999 the acquisition ofthe German company was approved with effect from 1 July 1999. On 14 September 1999. On 15 October 1999, the parties signed the loan agreement. The principal of the loan was fixed at DKK 4.9 billion corresponding to a market value of DKK 3.6 billion. The effective interest on the loan was 6.1 % per annum. The Capital loss associated with the first instalment on 30 June 2000 was DKK 222 million, which was claimed by the Danish company as a deduction in its tax return for 2000.

The Supreme Court affirmed the opinion of the High Court that section 34(5) (Danish statutes of limitation for controlled transactions) covered all types of adjustments of controlled transactions. The income years 1999 and 2000 were thus not time barred. The Court further noted the following :
The Supreme Court notes that the provision in section 2(1) of the Tax Assessment Act under which prices and terms of controlled transactions must comply with the “arm’s length principle” for tax purposes, according to the legislative history covers all relations between the parties, e.g. provision of services, loan agreements, transfer of assets, transfer for use of intangibles etc.

According to the provision the tax authorities are entitled to make adjustments of transactions between related parties where a transaction does not reflect what could have been obtained between unrelated parties.

The authority to make an adjustment covers all economic elements and other terms of relevance for taxation purposes including, for example, due date, recognition of interest and capital losses and the legal qualification of the transaction.

A loan agreement on zero-coupon terms concluded between related parties with retroactive effect may thus be adjusted by the tax authorities on the basis of section 2(1) of the Tax Assessment Act. The Supreme Court further concurs that there is no basis to conclude that a final and binding agreement between Swiss Re Copenhagen Holding ApS and the parent company on the terms of the loan had been concluded before the signing of the loan agreement on 15 October 1999. On this basis the Supreme Court upholds the decision.”

The Supreme Court thus held that the loan agreement infringed on the arm’s length principle as laid down in section 2 of the Tax Assessment Act, and that the adjustment made by the tax authorities was warranted.

 

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February 2, 2012 , , , , ,
Denmark vs. Bombardier, October 2013, Administrative Tax Court, SKM2014.53.LSR The issue in the case was whether the applicable rates under the cash pool arrangement were on arm’s length, i.e. in accordance with the transfer pricing requirements.

The Administrative Tax Court upheld most of the conclusions of the tax authorities. First, the Court found that the tax authorities were allowed to assess an arm’s length rate due to the lack of transfer pricing documentation. Second, the financial service fee of 0.25% was upheld. Third, the Court concluded that the rate on the short-term deposits and the corresponding loans (borrowed due to insufficient liquidity management) should be the same.

The Administrative Tax Court observed that there was very little or no creditor risk on these gross corresponding loans/deposits because of the possibility of offsetting the balance. Hence, according to the Court, there was no basis for a spread on the gross balance.

However, the rate spread on the net balance of the deposits was lowered from +1.18% to + 1.15%, equal to the borrowing rate spread. The Administrative Tax Court reasoned that the tax authorities had accepted the 1.15% rate spread as the market rate on loans made by the Danish subsidiary and that there were no facts indicating that the deposit rate should be different.

The Administrative Tax Court also remarked that the adjustment made by the tax authorities was not a recharacterization, but rather a price adjustment.

 

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October 7, 2013 , , , , , ,
Denmark vs Corp. October 2015, Supreme Court, case nr. SKM2015.659.HR
A Danish production company terminated a 10-year license and distribution agreement with a group distribution company one year prior to expiry of the agreement.

The distribution agreement was transferred to another group company and the new distribution company agreed as a successor in interest to pay a “termination fee” to the former distribution company.

However, the termination fee was paid by the Danish production company and the amount was depreciated in the tax-return.

The Danish company claimed that it was a transfer pricing case and argued that the tax administration could only adjust agreed prices and conditions of the agreement if the requirements for making a transfer pricing correction were met.

The Supreme Court stated that the general principles of tax law in the State Tax Act §§ 4-6 also applies to the related companies. Hence, the question was whether the termination fee was held for “acquiring, securing and maintaining the applicant’s income”, cf. the state tax act § 6.

The Supreme Court found that payment of the termination fee did not have a sufficient connection to the Danish company’s income acquisition for the payment to be tax deductible. The applicant was therefore not entitled to tax depreciation of the payment.

The Supreme Court ruled in favor of the Danish tax administration.

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October 8, 2015 , , , , ,
Denmark vs. Corp, December 2016, Tax Tribunal, SKM2017.115 The case relates to controlled transactions between a Danish company and its permanent establishment, as well as the calculation of taxable income of the permanent establishment. The Danish Tax Administration was entitled to make tax assessment in accordance with applicable Tax Law. The transfer pricing-documentation provided by the Company lacked a comparability analysis. The assessment was in line with the OECD Transfer Pricing Guidelines, but some corrections to the tax assessment were made. December 15, 2016 , ,
Denmark vs. Corp, March 2017, Tax Tribunal, SKM2017.187 In this case the Danish Tax administration had made an estimated assessment due to a insufficient TP documentation. In the assessment goodwill amortizations were included when comparing the operating income of the company to that of independent parties in a database survey.

The Tax Tribunal found that the tax administration was not entitled to make an estimated assessment under Article 3B (3) of the current Tax Control Act. 8 (now paragraph 9) and section 5 3, where the TP documentation provided a sufficient basis for assessing whether prices and terms were in accordance with the arm’s length principle.

According to the Tax Tribunal goodwill amortizations should not be included when comparing the operating income of the company to the operating income of independent parties in a database survey. Hence the assessment was reduced to DKK 0.

The case has been appealed to the Danish National Court by the tax authorities (where a decision was issued in March 2020).

 

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March 13, 2017 , , ,
Denmark vs. Danish Production A/S, Feb 2018, Tax Tribunal, SKM2018.62.LSR In this case, the Danish Tax Tribunal found that the tax administration had been entitled to make an estimated assessment, due to the lack of a comparability analysis in the company’s transfer pricing documentation.

The Tax Tribunal also found that the Danish company had correctly been chosen as tested party when applying the TNMM, although the foreign sales companies were the least complex. Information about the foreign sales companies was insufficient and a significant part of the income in the foreign sales companies related to sale of goods not purchased from the Danish production company.

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February 12, 2018 , , , ,
Denmark vs Microsoft Denmark, March 2018, Danish National Court, SKM2018.416.ØLR The Danish Tax Ministry and Microsoft meet in Court in a case where the Danish tax authorities had issued an assessment of DKK 308 million.

The Danish tax authorities were of the opinion that Microsoft had not been properly remunerated for performing marketing activities due to the fact that OEM sales to Danish customers via MNE OEM’s had not been included in the calculation of local commissions.

In court, Microsoft required a dismissal with reference to the fact that Sweden, Norway and Finland had either lost or resigned similar tax cases against Micorosoft.

The National Court ruled in favor of Microsoft.

The decision has now been appealed to the Supreme Court by the Danish tax ministery.

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March 28, 2018 , , , , , , , ,
Denmark vs Water Utility Companies, November 2018, Danish Supreme Court, Case no 27/2018 and 28/2018 These two triel cases concerned the calculation of the basis for tax depreciation (value of assets) in a number of Danish Water utility companies which had been established in the years 2006 – 2010 in connection with a public separation of water supply and wastewater utility activities.

The valuation of the assets would form the basis for the water utility companies’ tax depreciation. The transfer was controlled and subject to Danish arm’s length provisions.

The Supreme Court found that the calculation method (DCF) used by the Danish Tax Agency did not provide a suitable basis for calculating the tax value of the transferred assets. The Court stated that for water supply and wastewater treatment it is true that the companies are legaly obligated to provide these facilities and that the governmental regulation of the activity – the “rest in itself” principle – means that no income can be earned on the activities. However, the decisive factor is the value of these assets for the water utility companies – not the fact that no income could be earned on the activity.

The Supreme Court found that a method by which the regulatory value is calculated as an average of the written down value and the acquisition value (the so-called POLKA value) was a reasonable approach to value of the assets under the arm’s length provisions.

The Supreme Court did not have the basis to determine the POLKA value and the cases was returned to the Tax Agency for consideration.

The district court had come to another conclusion.

Case 27/2018
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Case 28/2018
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November 8, 2018 , ,
Denmark vs Microsoft Denmark, January 2019, Danish Supreme Court In this case, the Danish tax authorities were of the opinion that Microsoft Denmark had not been properly remunerated for performing marketing activities due to the fact that OEM sales to Danish customers via MNE OEM’s had not been included in the calculation of local commissions.

According to the Market Development Agreement (MDA agreement) concluded between Microsoft Denmark and MIOL with effect from 1 July 2003, Microsoft Denmark received the largest amount of either a commission of 25% in the income years 2004-2007 as consideration for its marketing efforts. , 20% or 18% depending on the volume of sales that MIOL had invoiced in Denmark, or the costs Microsoft Denmark had on marketing with the addition of 15%.

Microsoft Denmark’s commission did not take into account the sale of Microsoft products that occurred through the sale of computers by multinational computer manufacturers with pre-installed Microsoft software to end users in Denmark – (OEM sales).

In court, Microsoft required a dismissal.

In a narrow 3:2 decision the Danish Supreme Court found in favor of Microsoft.

“…Microsoft Denmark’s marketing may have had some derivative effect, especially in the period around the launch in 2007 of the Windows Vista operating system, which made higher demands on the computers. On the other hand, it must be assumed that also the recommendations of Microsoft products made by the multinational computer manufacturers under agreements between, among others, Dell and Microsoft Denmark’s American parent company, which, in return, gave discounts to computer manufacturers, may have had an effect on, among other things. sales of Package licenses in Denmark, whereby Microsoft Denmark, in its remuneration, benefited from this marketing effort. The significance of the various companies’ marketing efforts and the interaction between them has not been elucidated during the case, and we find it unlikely that Microsoft Denmark’s marketing had an effect on the sale of MNA OEM licenses in the US and other countries outside Denmark, which exceeded the importance of computer manufacturers marketing for the sale of package licenses, which were included in the basis for the remuneration of Microsoft Denmark.

Based on the above, we do not find that Microsoft Denmark’s remuneration for the company’s marketing efforts was not in accordance with the arm’s length principle.”

 

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January 31, 2019 , , , , , , ,
Denmark vs H Group, April 2019, Tax Tribunal, Case No. SKM2019.207 In this case intangibles had been transferred from a Danish subsidiary to a US parent under a written agreement. According to the agreement the Danish subsidiary – which had developed and used it’s own intangibles – would now have to pay royalties for the use of trademarks, know-how and patents owned by the US parent.

The tax authorities had issued an assesment on the grounds that the majority of the Danish company’s intangibles had been transferred to the US parent. In the assesment the value of the intangibles had been calculated based on the price paid when the US group acquired the shares in the Danish company.

H Group argued that the transferred intangibles no longer carried any value and that the Danish company now used intangibles owned by the US group.

The Tax Tribunal found that tax authorities had been entitled to make an assessment as the transaction had not been described in the Transfer pricing documentation. However, the Tribunal considered that the valuation based on the price paid when the US group acquired the shares in the Danish company was too uncertain and instead applied a relief-from-royalty method. 

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April 9, 2019 , , , , ,
Denmark vs MAN Energy Solutions, September 2019, Supreme Court, Case No BS-4280-2019-HJR A Danish subsidiary in the German MAN group was the owner of certain intangible assets. The German parent, acting as an intermediate for the Danish subsidiary, licensed rights in those intangibles to other parties.

In 2002-2005, the Danish subsidiary received royalty payments corresponding to the prices agreed between the German parent company and independent parties for use of the intangibles.

The group had requested an adjustment of the royalty payments to the Danish subsidiary due to withholding taxes paid on inter-company license fees received by the German Parent. This was rejected by the Danish tax authorities.

The Supreme Court found no basis for an adjustment for withholding taxes as the agreed prices between the German parent and the Danish Subsidiary matched the market price paid by independent parties.

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September 12, 2019 , ,
Denmark vs Adecco A/S, Oct 2019, High Court, Case No SKM2019.537.OLR The question in this case was whether royalty payments from a loss making Danish subsidiary Adecco A/S (H1 A/S in the decision) to its Swiss parent company Adecco SA (G1 SA in the decision – an international provider of temporary and permanent employment services active throughout the entire range of sectors in Europe, the Americas, the Middle East and Asia – for use of trademarks and trade names, knowhow, international network intangibles, and business concept were deductible expenses for tax purposes or not.

In  2013, the Danish tax authorities (SKAT) had amended Adecco A/S’s taxable income for the years 2006-2009 by a total of DKK 82 million.

Section 2 of the Tax Assessment Act. Paragraph 1 states that, when calculating the taxable income, group affiliates must apply prices and terms for commercial or economic transactions in accordance with what could have been agreed if the transactions had been concluded between independent parties.

SKAT does not consider it in accordance with section 2 of the Tax Assessment Act that during the period 2006 to 2009, H1 A/S had to pay royalty to G1 SA for the right to use trademark, “know-how intangibles” and “ international network intangibles ”.

An independent third party, in accordance with OECD Guidelines 6.14, would not have agreed on payment of royalties in a situation where there is a clear discrepancy between the payment and the value of licensee’s business. During the period 2006 to 2009, H1 A/S did not make a profit from the use of the licensed intangible assets. Furthermore, an independent third party would not have accepted an increase in the royalty rate in 2006, where the circumstances and market conditions in Denmark meant that higher profits could not be generated.

H1 A/S has also incurred considerable sales and marketing costs at its own expense and risk. Sales and marketing costs may be considered extraordinary because the costs are considered to be disproportionate to expected future earnings. This assessment takes into account the licensing agreement, which states in Article 8.2 that the termination period is only 3 months, and Article 8.6, which states that H1 A/S will not receive compensation for goodwill built up during the contract period if the contract is terminated.

H1 A/S has built and maintained the brand as well as built up “brand value” on the Danish market. The company has contributed to value of intangible assets that they do not own. In SKAT’s opinion, an independent third party would not incur such expenses without some form of compensation or reduction in the royalty payment, cf. OECD Guidelines 6.36 – 6.38.

If H1 A/S was not associated with the trademark owners, H1 A/S would, in SKAT’s opinion, have considered other alternatives such as terminating, renegotiating or entering into more profitable licensing agreements, cf. OECD Guidelines 1.34-1.35. A renegotiation is precisely a possibility in this situation, as Article 8.2 of the license agreement states that the agreement for both parties can be terminated at three months’ notice.

The control of the group has resulted in H1 A/S maintaining unfavorable agreements, not negotiating better terms and not seeking better alternatives.

In addition, SKAT finds that the continuing losses realized by the company are also due to the Group’s interest in being represented on the Danish market. In order for the Group to service the global customers that are essential to the Group’s strategy, it is important to be represented in Denmark in order to be able to offer contracts in all the countries where the customer has branches. Such a safeguard of the Group’s interest would require an independent third party to be paid, and the company must therefore also be remunerated accordingly, especially when the proportion of global customers in Denmark is significantly lower than in the other Nordic countries.

Adecco A/S submitted that the company’s royalty payments were operating expenses deductible under section 6 (a) of the State Tax Act and that it was entitled to tax deductions for royalty payments of 1.5% of the company’s turnover in the first half of 2006 and 2% up to and including 2009, as these prices were in line with what would have been agreed if the transactions had been concluded between independent parties and thus compliant  with the requirement in section 2 of the Tax Assessment Act (- the arm’s length principle) . In particular, Adecco A/S claimed that the company had lifted its burden of proof that the basic conditions for deductions pursuant to section 6 (a) of the State Tax Act were met, and the royalty payments thus deductible to the extent claimed.

According to section 6 (a) of the State Tax Act expenses incurred during the year to acquire, secure and maintain income are deductible for tax purposes. There must be a direct and immediate link between the expenditure incurred and the acquisition of income.

The company hereby stated that it was not disputed that the costs were actually incurred and that it was evident that the royalty payment was in the nature of operating costs, since the company received significant economic value for the payments.

The High Court ruled in favor of the Danish tax authorities and concluded as follows:

Despite the fact that, as mentioned above, there is evidence to suggest that H1 A/S’s payment of royalties for the use of the H1 A/S trademark is a deductible operating expense, the national court finds, in particular, that H1 A/S operates in a national Danish market, where price is by far the most important competitive parameter, that the company has for a very long period largely only deficit, that it is an agreement on payment to the company’s ultimate parent company – which must be assumed to have its own purpose of being represented on the Danish market – and that royalty payments must be regarded as a standard condition determined by G1 SA independent of the market in which the Danish company is working, as well as the information on the marketing costs incurred in the Danish company and in the Swiss company compared with the failure to respond to the relevant provocations that H1 A/S has not lifted the burden of proof that the payments of royalties to the group-affiliated company G1 SA, constitutes a deductible operating expense, cf. section 6 (a) of the State Tax Act. 4.5 and par. 4.6, the national court finds that the company’s royalty payment cannot otherwise be regarded as a deductible operating expense.

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October 28, 2019 , , , , , , , ,
Denmark vs Pharma Distributor A A/S, March 2020, National Court, Case No SKM2020.105.OLR The case concerned a Danish group engaged in distribution of pharmaceuticals. The TP documentation showed, using the TNM method, that the company’s earnings (EBIT margin) were, on average, significantly below an arm’s length range of net profit (benchmark), but by disregarding, among other things, the annual goodwill amortization of DKK 57.1 million, the average EBIT margin was within the benchmark.

The goodwill that was being amortized in Pharma Distributor A A/S had been determined under a prior acquisition of the company and later, due to a merger with the acquiring danish company, booked in Pharma Distributor A A/S.

The main question in the case was whether Pharma Distributor A A/S were entitled to disregard the goodwill amortization in the comparability analysis. The national tax court had ruled in favor of the company, but the national court reached the opposite result. Thus, the National Court found that the goodwill in question had to be regarded as an operating asset, and therefore the depreciation had to be regarded as operating expenses when calculating the net profit (EBIT margin).

In 2017 the Danish tax tribunal found in favor of Pharma Distributor A A/S

However, The Danish National Court found that the controlled transactions had not been priced in accordance with the arm’s length principle in section 2 (2) of the Tax Assessment Act. 1, and that the tax authorities was therefore basically justified in assessing the income of Pharma Distributor A A/S. But there was no basis for adjustment for the income year 2010, where the EBIT margin of the company (including goodwill amortization) was within the interquartile range of the benchmark.

The National Court further found that Pharma Distributor A A/S had not demonstrated that the companies whose results were included in the benchmark possessed goodwill that was simply not capitalized and which corresponded approximately to the value of the goodwill in Pharma Distributor A A/S. Therefore, the National Court did not find that adjusting for goodwill amortization in the comparability analysis, would make the comparison more correct.

Pharma Distributor A A/S also claimed that special commercial conditions (increased price competition, restructuring , etc.) and not incorrect pricing had led to lower earnings. The Court found that such conditions had not been demonstrated by the company.

On this basis, the National Court found that the tax authorities was entitled to make the assessment of additional income in FY 2006-2009, but not for FY 2010.

The court found that, when adjusting the taxable income, an individual estimate must be made for each year, based on what income the defendants could be assumed to have obtained if they had acted in in accordance with the arm’s length principle. The court referred the case for re-assessment of the taxable income for FY 2006-2009.

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March 11, 2020 , , , , , ,
Denmark vs Icemachine Manufacturer A/S, June 2020, National Court, Case No SKM2020.224.VLR At issue was the question of whether the Danish tax authorities had been entitled to make a discretionary assessment of the taxable income of Icemachine Manufacturer A/S due to inadequate transfer pricing documentation and continuous losses. And if such a discretionary assessment was justified, the question of whether the company had lifted the burden of proof that the tax authorities’ estimates had been clearly unreasonable.

The Court ruled that the transfer pricing documentation provided by the company was so inadequate that it did not provide the tax authorities with a sufficient basis for determining whether the arm’s length principle had been followed. The tax authorities had therefore been entitled to make a discretionary assessment of the taxable income. For that purpose the Court found that the tax authorities had been justified in using the TNM method with the Danish company as the tested party, since sufficiently reliable information on the sales companies in the group had not been provided.

 

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June 8, 2020 , , , , ,
Denmark vs. Adecco A/S, June 2020, Supreme Court, Case no BS-42036/2019-HJR The question in this case was whether royalty payments from a loss making Danish subsidiary Adecco A/S (H1 A/S in the decision) to its Swiss parent company Adecco SA (G1 SA in the decision – an international provider of temporary and permanent employment services active throughout the entire range of sectors in Europe, the Americas, the Middle East and Asia – for use of trademarks and trade names, knowhow, international network intangibles, and business concept were deductible expenses for tax purposes or not.

In  2013, the Danish tax authorities (SKAT) had amended Adecco A/S’s taxable income for the years 2006-2009 by a total of DKK 82 million.

Adecco A/S submitted that the company’s royalty payments were operating expenses deductible under section 6 (a) of the State Tax Act and that it was entitled to tax deductions for royalty payments of 1.5% of the company’s turnover in the first half of 2006 and 2% up to and including 2009, as these prices were in line with what would have been agreed if the transactions had been concluded between independent parties and thus compliant  with the requirement in section 2 of the Tax Assessment Act (- the arm’s length principle) . In particular, Adecco A/S claimed that the company had lifted its burden of proof that the basic conditions for deductions pursuant to section 6 (a) of the State Tax Act were met, and the royalty payments thus deductible to the extent claimed.

According to section 6 (a) of the State Tax Act expenses incurred during the year to acquire, secure and maintain income are deductible for tax purposes. There must be a direct and immediate link between the expenditure incurred and the acquisition of income.

The company hereby stated that it was not disputed that the costs were actually incurred and that it was evident that the royalty payment was in the nature of operating costs, since the company received significant economic value for the payments.

The High Court ruled in favor of the Danish tax authorities and concluded as follows:

Despite the fact that, as mentioned above, there is evidence to suggest that H1 A/S’s payment of royalties for the use of the H1 A/S trademark is a deductible operating expense, the national court finds, in particular, that H1 A/S operates in a national Danish market, where price is by far the most important competitive parameter, that the company has for a very long period largely only deficit, that it is an agreement on payment to the company’s ultimate parent company – which must be assumed to have its own purpose of being represented on the Danish market – and that royalty payments must be regarded as a standard condition determined by G1 SA independent of the market in which the Danish company is working, as well as the information on the marketing costs incurred in the Danish company and in the Swiss company compared with the failure to respond to the relevant provocations that H1 A/S has not lifted the burden of proof that the payments of royalties to the group-affiliated company G1 SA, constitutes a deductible operating expense, cf. section 6 (a) of the State Tax Act. 4.5 and par. 4.6, the national court finds that the company’s royalty payment cannot otherwise be regarded as a deductible operating expense.

Adecco appealed the decision to the Supreme Court.

The Supreme Court overturned the decision of the High Court and ruled in favor of Adecco.

The Supreme Court held that the royalty payments had the nature of deductible operating costs. The Supreme Court also found that Adecco A/S’s transfer pricing documentation for the income years in question was not insufficient to such an extent that it could be considered equal to lack of documentation. The company’s income could therefore not be estimated by the tax authorities. Finally, the Supreme Court did not consider that a royalty rate of 2% was not at arm’s length, or that Adecco A/S’s marketing in Denmark of the Adecco brand provided a basis for deducting in the royalty payment a compensation for a marketing of the global brand.

 

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June 25, 2020 , , , , , , , , ,