New location for CORIT Advisory P/S and CORIT Academic

The future premises for CORIT Advisory P/S and CORIT Academic have now been decided. We have chosen to locate the office in Kongens Lyngby in the northern part of greater copenhagen.

The adress is: Lyngby Hovedgade 17, 2nd. floor., DK-2800 Kongens Lyngby.

The choice is made on the basis of a numbers of relevant factors. Kongens Lyngby is a university city with a large population of innovative and important companies. Moreover, the city has formulated a strategy to become a significant knowledge- and university city in northern Europe. Moreover, the city has the ambition to be an international hotspot for labour, culture and trade.

This strategy is perfectly aligned with the CORIT ambition and we consider it a perfect match for future devepment of CORIT and we also look forward to participate in the fulfillment of the city’s strategy.

We look forward to welcome you in our new offices.

Submission of tax management Ph.D.-thesis by CORIT member Stuart Webber – Corporate Profit Shifting and the Multinational Enterprise.

The thesis consist of 5 chapters:

  •  Introductory Chapter: Evidence of Corporate Profit Shifting
  • Thin Capitalization and Interest Deduction Regulations: A Worldwide Survey
  • The Tax Efficient Supply Chain: Considerations for Multinationals
  • Escaping the U.S. Tax System: from Corporate Inversions to Re-domiciling
  • The IRS Investor Model

The dissertation analyzes ways in which Multinational Enterprises (MNEs) shift profits from one country to another to reduce their income tax expense. This is an important topic for a number of reasons. From a country‘s perspective, its income tax rates and policies can have a significant impact upon its tax revenue, economic competitiveness, and the vibrancy of its economy. From the MNE‘s perspective, income tax rates and policies determine a firm‘s tax obligations, and thus affect net income and enterprise value. The dissertation examines several ways in which MNEs shift profits to reduce income taxes, and consists of five chapters.

The introductory chapter reviews the economic evidence demonstrating firms shift profits from one country to another in response to tax rates. In the past two decades a number of economic studies have shown firms use tax and accounting techniques to shift reported profits to low tax jurisdictions, and that chapter reviews key articles that have demonstrated this. The second paper explains how MNEs finance international investments to shift interest income to low-tax jurisdictions. It reviews government tax policies in a number of countries that have been enacted to limit interest income shifting, and recommends an approach to control this activity. The third paper examines tax efficient supply chains, in which tax departments and supply chain organizations collaborate to site business operations to achieve supply chain objectives and reduce tax obligations. The fourth chapter analyzes how some U.S.-headquartered firms have moved their corporate headquarters from the U.S. to tax havens, to reduce their tax expense and avoid U.S. international tax policies. The fifth and final chapter examines new U.S. tax regulations that propose to value intellectual property transfers in the same way outside investors would, which the U.S. Internal Revenue Service (IRS) calls its ―investor model. It also makes recommendations concerning how the investor model can be improved. This dissertation draws upon a number of academic disciplines, including economics, finance, supply chain management, and tax law. It does not fit into a single academic category, and it seeks to make a contribution by drawing upon these various disciplines to recommend ways countries can tax economic activity in fair and effective ways, and suggest ways firms can minimize tax obligations while still complying with international tax laws.

International Transfer Pricing

On March 10th 2011, Christian Plesner Rossing, Copenhagen Business School, Department of Accounting & Auditing, defended his PhD entitled: International Transfer Pricing in Theory and Practice.

The dissertation consist in a literature review and three empircal papers, illustrating the way management control and cost accounting systems can be designed for transfer pricing tax compliance purposes in the MNE.

Christian will continue in academia and do more research on international transfer pricing, integrating the accounting and taxation discipline.

If you are interested in research/teaching collaboration, Christian can be reached at cro.acc@cbs.dk

CORIT

Nordic Private Equity Conference

The Nordic Private Equity Conference Team invites you to one of the biggest events within private equity and buy-out in Northern Europe this fall: TheNordic Private Equity Conference at Copenhagen Marriott Hotel onNovember 12, 2010.
Managing Directors, Partners and alike from top-tier private equity funds, institutional investors, investment banks, consulting companies, and company managers will meet on this day to discuss and reflect upon how companies, managers and owners create value in this turbulent environment.

The conference is hosted in co-operation with Danish Venture Capital & Private Equity Association (DVCA) and Copenhagen Business School and will consist of 3 keynote speeches and 8 panels providing their view on intriguing topics within the industry. These panels are composed by top professionals within private equity from companies such as Goldman Sachs Capital Partners, Kohlberg Kravis Roberts, J.P. Morgan, McKinsey & Company, Boston Consulting Group, EQT, Axcel, Credit Suisse, Morgan Stanley, TDC, Booz & Co. and many, many more.

For more information, please go to http://www.pe-conference.com/.

Invitation

Agenda

Poster

New publications available

The two-part article “Classification and Treatment of Hybrid Financial Instruments and Income Derived Therefrom under EU Corporate Tax Directives” by Jakob Bundgaard is now available on our website. The two-part article is published in European Taxation no. 10 and no. 11 2010. The author addresses the application of EU tax directives on hybrid financial instruments. In Part 1, the applicability of the Parent-Subsidiary Directive and the Interest and Royalties Directive is analyzed. In Part 2, unilateral measures of Member States to combat cross-border arbitrage are discussed. Moreover, Part 2 contains an analysis of the holding requirements under the directives and the application of the EU Arbitration Convention.

New book: Transfer Pricing and the Arm’s Length Principle in International Tax Law

CORIT-partner Jens Wittendorff’s doctoral thesis has now been published in English. The book contains a comparative analysis of the legal basis for the arm’s length principle and the contents of the arm’s length rules in US tax law as well as in the OECD Model Tax Convention and Transfer Pricing Guidelines. It includes a thorough review of international case law on transfer pricing from the United States, Canada, Australia, United Kingdom, Germany, France, the Netherlands, Denmark, Sweden and Norway. The book ends with an analysis of the issues associated with the application of the arm’s length principle for multinational enterprises in a global economy.

Click here for more information

Appointment of Honorary Professors

To celebrate the appointment of two Honorary Professors at the Department of Business Law, CORIT-member Jakob Bundgaard and CORIT-partner Jens Wittendorff will give their inaugural speeches on Friday September 17th 2010 in the Tuborg Auditorium (M2) at 1.00pm at Aarhus School of Business.

The Aarhus School of Business will host a reception after the inaugural speeches. The speeches will be held in Danish.

CORIT discussion paper series expands

CORIT expands its discussion paper series to include student thesis’es of a very high standard. For future purposes CORIT discussion papers will include student thesis’es within the field of international taxation that have been assessed as extraordinary achievements. We welcome students from all universities to submit their work for scientific review by CORIT members.

As student contributions to the Discussion Paper Series we have released:

Discussion paper no. 6: The Personal Injury Exclusion: Arguably Arbitrary by Kim David Lexner.

Discussion paper no. 7: Selected issues in the U.S.-DK Tax Treaty: Permanent establishment in relation to E-Commerce transactions and the distinction between payment for services and payment for intangible property rights by Kim David Lexner.

Farewell reception

A farewell reception for Jakob Bundgaard will be held on Tuesday 24 August at 3 pm at Augustinus Fondens Mødelokale, Solbjerg Plads 3, 2000 Frederiksberg.Jakob Bundgaard is leaving CBS as of 1 September to become a Honorary Professor at Aarhus School of Business.