Supreme Court Overrules High Court in the Adecco Transfer Pricing Case (Trademark Licence Agreement)

Journal
Bjørnholm, N.; Tolstrup, B.
Denmark
International Transfer Pricing Journal 2020 (Volume 27), No. 6
FormatPDF
EUR
40
| USD
45
(VAT excl.)

On 25 June 2020, the Danish Supreme Court overruled the High Court and sided with the taxpayer in the Adecco case. The dispute concerned the arm’s length nature of trademark royalties paid by Adecco Denmark to the Swiss related intellectual property owner and parent. This article discusses the ruling in more detail and provides some comments on what can be deduced from it.