International Tax Report
Revenue defeat in first substantial transfer-pricing case to reach the Danish Supreme Court
Law firm Kromann Reumert has successfully defended Microsoft in the first transfer pricing case ever to reach the Danish Supreme
Court. The Ministry of Taxation’s claims were based on substantive as well as procedural allegations, raising legal questions
of principle and of general importance for Danish transfer-pricing matters. In this article, Arne Møllin Ottosen and Stine
Andersen account for the most central legal issues and the broader implications of the judgment for Danish transfer-pricing
matters and beyond.